Our Blog

EDWARD M. ROBBINS, JR. , ROBERT S. HORWITZ AND MICHAEL GREENWADE to Speak at Upcoming Strafford Webinar on Foreign Information Return Penalties After Farhy – July 18, 2024

We are pleased to announce that Edward M. Robbins, Jr., Robert S. Horwitz and Michael Greenwade will be speaking at the upcoming Strafford webinar “Foreign Information Return Penalties After Farhy: Impact of DC Circuit Court Decision” Thursday, July 18, 2024, 10:00 a.m. – 11:50 a.m. (PST).

In Farhy v. Commissioner 160 T.C. No. 6 (T.C. Apr. 3, 2023), the Tax Court ruled that the IRS did not have the authority to assess and collect penalties under IRC Section 6038(b) for failure to file Forms 5471. On appeal, the D.C. Circuit Court overturned the Tax Court decision. This case has ramifications for other forms, including Forms 5472, 8858, 8938, 926, and perhaps even Form 3520.

International tax advisers need to know how the IRS will likely respond to this decision, how this decision impacts taxpayers in other circuits, and the impact of a potential appeal to the U.S. Supreme Court. This webinar will examine the impact of Farhy v. Commissioner on foreign information return reporting penalties and detail the actions international tax practitioners need to take in light of this case, including the recent D.C. Circuit Court ruling. 

Click Here for More Information

< Back to all Posts