By Jonathan Prokup Over the weekend, a variety of Canadian news sources (see, e.g., the Financial Post and the Edmonton Journal) reported on anticipated guidance from the IRS, which would result in the waiver of penalties on certain U.S. citizens living in Canada for past failures to file Form TD F 90-22.1, commonly known as [...]
Archive for the ‘International’ category
Tax Foundation: Rethinking U.S. Taxation of Overseas Operations
December 1, 2011By Jonathan Prokup Our in-house and private-practice corporate readers will likely enjoy one of the Tax Foundation’s newest reports: Rethinking U.S. Taxation of Overseas Operations. As the abstract describes: The United States produces a third of the world’s wealth but contains less than 5 percent of the world’s population. This disparity pushes many U.S. businesses [...]
Businesses Prepare For The End Of The Euro; Will Treasury Do The Same?
November 29, 2011By Jonathan Prokup According to the Financial Times, companies around the world are preparing for the possibility of a breakup of the euro. Given the currency devaluation that would likely occur in countries coming out of the euro, these companies are preparing for the impact that such an event would have on balance sheets (e.g., [...]
Merck (Shering Plough) v. U.S.: Will One Taxpayer’s Loss Benefit Other Taxpayers Grappling With The Codified Economic Substance Doctrine?
June 21, 2011By Jonathan Prokup The Third Circuit yesterday issued a harshly worded rebuke to the taxpayer in Merck v. United States, No. 10-2775 (Jun. 20, 2011), affirming the District Court’s decision that the taxpayer’s swap-and-assign transaction was really a disguised loan that gave rise to Subpart F income. (See TaxProfBlog for a link to the opinion.)
FBAR Penalties: The IRS Lays Down The Law On Quiet Disclosures
May 23, 2011By Jonathan Prokup As part of its current Offshore Voluntary Disclosure Initiative (“OVDI”), the IRS is strongly encouraging taxpayers against making so-called “quiet” disclosures, in which taxpayers file amended tax returns, pay the applicable taxes and interest, and hope that the IRS doesn’t identify them for further investigation. These disclosures are described as quiet because [...]
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Jonathan Prokup
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George Connelly, Jr.
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