U.S. persons who invest in foreign activities often have U.S. reporting obligations. A common international reporting requirement for many U.S. persons is IRS Form 5471, Information Return of U.S.

In the recent U.S. Tax Court’s decision in Farhy v. Commissioner 160 T.C, No. 6 (April 3, 2023), the court ruled that the Internal Revenue Service lacks authority to assess and collect penalties from ...