Taxpayers Should Be Prepared to Still File While CTA Beneficial Ownership Reporting Requirements are on Hold

Taxpayers are no longer required to report beneficial ownership information (“BOI”) to the U.S. Financial Crimes Enforcement Network (“FinCEN”). At least, for now. In a January 2, 2025, post on its webpage following a merits panel in the Fifth Circuit’s decision to uphold the universal injunction issued by the U.S. District Court for the Eastern…

Farhy Lives: Tax Court Declines to Follow the Farhy D.C. Circuit Ruling in Mukhi Case

For taxpayers who have received penalties for failure to file, or late filing of foreign information reporting requirements (e.g., Forms 5471, 5472, 8858 or 8865), recent decision out of the U.S. Tax Court bears great significance. On April 3, 2023, the U.S. Tax Court issued a ruling in Farhy v. Commissioner, stating that the Internal Revenue…

Demystifying Alternative Risk Transfer Programs and their Tax Consequences

The current insurance market has become difficult for everyone involved. Insurers are withdrawing from entire markets. Fewer insurers are offering quotes on applications while underwriters are asking for additional information as part of the application process. Reinsurers are tightening underwriting standards, further constricting coverage. Read full article >>

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