In Mendu v. United States, the Court of Federal Claims held that penalties for failure to timely file a Report of Foreign Bank and Financial Accounts (FBAR), commonly known as “FBAR penalties,” were not subject to the Flora full payment rule, which requires a plaintiff to make payment of the full tax amount before they bring suit in the Court of Federal Claims or any US district court for the refund of any “internal-revenue tax.”

Welcome to our first quarter issue of the Private Wealth Newsletter. Our featured insight for this issue is a discussion of the passage of the Corporate Transparency Act by the United States to introduce federally-mandated beneficial ownership reporting obligations for US corporations and limited liability companies. We also include insights…

On 28 September 2020, the Treasury Inspector General for Tax Administration published the Final Audit Report (“Report”). The Report was originally initiated to determine the effectiveness of the IRS efforts in ensuring compliance with the expatriation tax provisions under sections 887 and 877A, and related efforts to reduce taxpayer’s burden.

Click here to request the latest edition of this newsletter.  Feature Malaysia: Wealth management and tax planning in the wake of COVID-19 Case Summaries Brazil Private Letter Ruling No. 41 of 31 March 2020 — tax treatment of trust distributions to Brazilian beneficiaries France Wealth tax — The refusal to…