The United States Tax Court’s recent decision in Farhy v. Commissioner prevents the Internal Revenue Service (IRS) from assessing and collecting penalties from taxpayers for failure to file Form 5471, Information Return of US Persons With Respect to Certain Foreign Corporations.

On 2 November 2022, the Swiss Federal Supreme Court upheld the Swiss Federal Administrative Court’s ruling that information can be exchanged to investigate criminal tax matters pursuant to an information exchange request by a foreign tax authority. However, use of the information exchanged for non-tax enforcement purposes is impermissible.