Tag Archives: penalties

Smith v. Comm’r: Before You Take that Business-Related Tax Loss, Ask “Does My Business Have a Bona Fide Purpose?”

Last fall, the U.S. Tax Court decided the case of Smith v. Comm’r.[1] It’s not a pivotal case, but it stands as a good reminder of the adage “you don’t get something for nothing.” At the heart of the case was a complicated tax planning strategy using an ...

What To Do If You Have Delinquent International Information Tax Returns

A U.S. taxpayer with international holdings and interests may not be fully compliant with U.S. tax reporting obligations even though they have currently reported all foreign source income on their annual tax return, filed Form 8938: Statement of Foreign Assets, and submitted a timely FBAR. Some taxpayers may also have ...