Form 5471 Penalty Litigation Demonstrates how Federal Courts Work

Form 5471 Category 1 Rarely Applies, and Never* for a New U.S. Resident

Don’t Forget Section 367(b) when Working with Foreign Corporations

Why the Disregarded Entity Election is Not Necessarily a Good Idea

Why Treaty Nonresidents Must File Form 5471

Strategies to Deal with CFCs with Lifestyle-level Net Profit