Foreign Accounts Compliance

Forms 8938, 5471, 3520 3520-A, 5472, 8865, and 926 and Assessable vs. Nonassessable Penalties

In the recent case of Farhy v. Commissioner, the Internal Revenue Service assessed penalties against Alon Farhy for failing to ...
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Required Minimum Distributions

Internal Revenue Code (“IRC”) Section 403(b) annuities, Section 401(k) plans, and Section 408 individual retirement arrangements, whether individual retirement accounts ...
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Supreme Court Signals Reversal in Bittner

On November 2 the Supreme Court held oral arguments in Bittner,[1] on whether the failure to timely file a Financial ...
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Supreme Court Grants Certiorari in Bittner

In United States v. Bittner, the U.S. Court of Appeals for the Fifth Circuit held that the $10,000 penalty for ...
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