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Expert Analysis

How Foreign Info Return Penalty Case May Benefit Taxpayers

By Sarah Constantine, Jonathan Green and Rebecca Gordon (May 24, 2023, 5:42 PM EDT) -- On April 3, in Farhy v. Commissioner, the U.S. Tax Court rejected the Internal Revenue Service's efforts to impose penalties on a taxpayer for failure to file foreign corporation information return Form 5471. According to the Tax Court, foreign information return penalties are neither taxes nor assessable penalties and, therefore, the IRS lacks statutory authority under Internal Revenue Code Section 6038 to assess and collect such penalties....

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