The IRS has recently notified the AICPA’s Foreign Trust Task Force that the IRS plans over the next few months to send out letters to taxpayers who filed Form 3520, Annual Return to Report ...
The IRS continues to aggressively enforce certain foreign information return obligations. In many cases, these enforcement efforts are automatic—that is, the agency simply imposes the applicable ...
New Proposed Guidance From the IRS on Foreign Trust Transactions and Large Gifts From Non-US Persons
On May 8, the IRS issued proposed regulations addressing matters related to foreign trusts and large gifts received from "nonresident aliens" (NRAs) by a U.S. person. See REG-124850-08 (proposed ...
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