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U.S. Assists Finland in Investigation of Payment Cardholders for Unreported Income via John Doe Summons - Will the Use of LLCs and Trusts Conceal Their Identities?

USA - May 10 2019 The United States petitioned the court to authorize the summonses at the request of the government of Finland under the income tax treaty between...

Jennifer Migliori, Hope P. Krebs, Anthony D. Martin, Jon Grouf, Thomas W. Ostrander.

IRS Announces New and Updated Voluntary Disclosure Program for Foreign and Domestic Tax Issues

USA - December 5 2018 The UVDP is only applicable to taxpayers who make “timely voluntary disclosures” and who fully cooperate with the IRS. On November...

Megan R. Worrell, Jennifer Migliori, Hope P. Krebs, Anthony D. Martin, Jon Grouf, Thomas W. Ostrander.

New Annual U.S. Tax Reporting Required for Foreign-Owned U.S. Limited Liability Companies and Other U.S. Business Entities

USA - December 15 2016 On December 13, 2016, the U.S. Treasury Department and Internal Revenue Service issued final regulations mandating that foreign-owned U.S. limited...

Megan R. Worrell, Tom Schmuhl, Andrew L. Odell, Anastasios G. Kastrinakis, Hope P. Krebs, Eberhard H. Röhm, Miriam O. Hyman, Lee J. Potter, Jr., Jon Grouf, Thomas W. Ostrander.