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Failure-to-File Foreign Corporations Internal Revenue Service

Mayer Brown

Relieved Taxpayers: US Tax Court Reaffirms that IRS Cannot Assess Failure-to-file Penalties

Mayer Brown on

Every parent remembers when their child learns the meaning of the word “no.” That moment often comes as a shock because, up until that moment, most children are models of obedience and unconditional trust. When children learn...more

Fox Rothschild LLP

Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties

Fox Rothschild LLP on

In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the taxpayer failed to file Forms 5471 reporting his interest...more

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