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Article: IRS seeks FC and NRA nonfilers.(foreign corporations, nonresident aliens)
- Article from:
- The Tax Adviser
- Article date:
- November 1, 2003
CopyrightCOPYRIGHT 2003 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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As part of its initiative to seek out nonfilers and underreporters of income, the IRS issued Notice 2003-38, under which it waived certain penalties for nonresident aliens (NRAs) and foreign corporations (FCs) that failed to file income tax returns. The waivable penalties included the denial of benefits for deductions and credits (under Sec. 874(a) or 882(c)(2)) and the Sec. 6651 (f) 75% fraudulent-failure-to-file penalties. To qualify, a taxpayer had to pay its tax liability for each outstanding return year (plus interest and other penalties, as determined by the IRS) and agree to cooperate with any IRS requests to calculate and pay the liability. This limited amnesty ...
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