Once Removed Episode 18: The Reciprocal Trust Doctrine
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
$50,000 or $2.72 million? Those are the penalty amounts for the non-willful failure to timely file to report foreign financial accounts at issue in U.S. v Bittner, which will be argued before the U.S. Supreme Court in...more