Fox Rothschild LLP

The Treasury Department recently released final regulations requiring U.S. single member LLCs owned by a foreign person to be treated as corporation for purposes of filing Form 5472, Information Return
Continue Reading Beginning January 2017, Disregarded U.S. LLC’s with Foreign Owners Must Report Tax Information to IRS

The IRS released an advanced version of Revenue Procedure 2016-56 that requires three more countries – Israel, the Republic of Korea and Saint Lucia – to participate in the automatic
Continue Reading Israel, the Republic of Korea and Saint Lucia Will Now Provide IRS Information on Bank Interest paid to Nonresident Aliens

On November 30th, a federal district court in California entered an order authorizing the IRS to serve a John Doe Summons on Coinbase Inc. seeking information about U.S.
Continue Reading Court Authorizes IRS to Seek Identities of Bitcoin Users and Users of Other Virtual Currencies

Effective November 18, 2016, Revenue Procedure 2016-57 established the Small Business/Self-Employed (“SB/SE”) Fast Track Mediation Collection (“FTMC”) program to allow taxpayers and the IRS to resolve disputes quickly with an
Continue Reading IRS Unveils Fast Track Mediation Collection Program, Offering Expedited Resolution for Certain Collection Cases

On September 8, 2016, the IRS issued its final report on taxpayer compliance through fiscal year 2015 (the federal government’s fiscal year begins on October 1 and ends on September
Continue Reading Trends in IRS Compliance Activities Through Fiscal Year 2015