Feature Article 
Foreign Corporations, Form 5471, and the Perils of Offshore Noncompliance
Form 5471 is required to be filed by United States (U.S.) persons—citizens, resident aliens, domestic partnerships, and corporations, and certain estates and trusts—who are officers, directors, or 10... Manasa Nadig, EA
Spring 2026,
Feature Article,
FBAR, Schedule C, GILTI, Schedule E, Form 8938, Form 926, Form 5471, Form 3520, Form 3520-A, fair market value, Schedule A, CDP, §965, controlled foreign corporation, CFC, Schedule I, FMV, Schedule F, Schedule B, Farhy v. Commissioner, §6038(c), foreign corporation, offshore noncompliance, §6679, §6046, §6038B(c), §318, Treas. Reg. §1.6046-1(i), §958(a), §958(b), Schedule G, §6013, Schedule H, Schedule M, Schedule O, Schedule P, Schedule Q, Schedule R, §6677, Raj J. Mukhi
Feature Article
How to Handle Foreign Informational Form Penalties
It was approximately two years ago when the tax law equivalent of a 7.0 earthquake came in the form of a decision from the United States Tax Court when it issued its decision in the case of Farhy v. Commi... David Woods, EA, USTCP, NTPI Fellow®
Fall 2025,
Feature Article,
collection due process, §6038, §6751(b), Form 8938, §6330, Form 926, Form 5471, Form 8865, Form 3520, Form 5472, §6201(a), Farhy v. Commissioner, §6038(a), §6038(b), Mukhi v. Commissioner, §6038(c), Safdieh v. Commissioner, first-time abatement, foreign informational form penalty