Questionable IRS Penalties for the Late Reporting of Offshore Trust Transactions
Robert Adler’s article, Questionable IRS Penalties for the Late Reporting of Offshore Trust Transactions, was published in Bloomberg BNA on October 27, 2017. In the article, Bob discusses the dubious grounds relied on by the IRS to impose the greater of two alternative penalties for the late filing of Form 3520 reporting offshore trust transactions. He points out four reasons that the IRS’ position is problematic. He explains that it contradicts the legislative history of Section 6048, the grantor trust rules, the well-established judicial principle that ambiguities in a statute are to be resolved in favor of the taxpayer, and the IRS’ own guidance to taxpayers applying the statute.
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