International Tax

In early November 2020, the IRS updated the terms of the Delinquent International Information Return Submission Procedures (Procedures). The Procedures…

As part of tax reform initiatives in 2017, Section 965 of the Tax Cut and Jobs Act (TCJA) requires that…

Holders of bank accounts outside the United States may be required to file FinCEN Form 114, Report of Foreign Bank…

On July 23, 2020, the Department of the Treasury and the Internal Revenue Service (collectively, Treasury) published in the Federal…

The IRS recently announced a new area of focus under its issue-based audit strategy program focusing on Internal Revenue Code…

The Internal Revenue Service (IRS) is continuing to increase its focus on cross border transactions and their reporting requirements. While…