On April 3, 2023, the U.S. Tax Court ruled in Farhy v. Commissioner[1] that the IRS lacks statutory authority to assess Form 5471 penalties under I.R.C. § 6038(b)(1) or

Continue Reading IRS Lacks Statutory Authority to Assess International Information Return Penalties: U.S. Tax Court

On 16 February 2022, the Netherlands and Colombia signed a tax treaty for the elimination of double taxation and the prevention of tax evasion and avoidance. The Treaty prevents double

Continue Reading The Netherlands and Colombia Have Signed a Tax Treaty

Greenberg Traurig Global Tax Practice Co-Chair Barbara T. Kaplan comments on FBAR (Report of Foreign Bank and Financial Accounts) penalty disputes, in an article published July 10 by Law360. Read


Continue Reading Barbara Kaplan Quoted in Law360 article, ‘International Tax Cases to Watch in the 2nd Half of 2020’

On Aug. 9, 2019, the IRS issued proposed regulations (Proposed Regulations) addressing the U.S. federal income tax treatment of cross-border cloud transactions. The Proposed Regulations will not become effective until
Continue Reading IRS Clarifies U.S. Tax Treatment of Cross-Border Cloud and Other Online Transactions in Proposed Regulations