On April 3, 2023, the U.S. Tax Court ruled in Farhy v. Commissioner that the IRS lacks statutory authority to assess Form 5471 penalties under I.R.C. § 6038(b)(1) or (2). As a result, the IRS cannot proceed with the collection of the penalties against the taxpayer. In recent years, the IRS has aggressively enforced foreign information return penalties, including the penalty for failing to file timely and complete Forms 5471. Farhy may have significant implications for taxpayers who have...

Read more

EIB President Werner Hoyer will lead a delegation to Washington DC between April 10-16 to join policymakers and fellow Multilateral Development Banks in forging responses to global challenges Stronger international partnership on climate action, investment in green tech and support for Ukraine will top the EIB agenda in Washington in a series of meetings on the margins of IMF/WBG events. An EIB delegation led by President Werner Hoyer, as well as Vice-Presidents Ambroise Fayolle, Teresa Czerwińska, Ricardo Mourinho and  Thomas Östros will meet...

Read more

I just interviewed ChatGPT. I was in a jam. I had volunteered to write a blog about ChatGPT. ChatGPT is taking off faster than any technology or innovation I’ve seen in a long while. It attracted an astounding 1 million users in 5 days and over 100 million in just 2 months. Since CLA works with over 10,000 healthcare and life science clients, we don’t want any of them to get left behind by new innovations. Rather than wait for...

Read more

Generative AI is a type of Artificial Intelligence (AI) that focuses on creating new data rather than recognizing patterns in existing data. This type of AI uses deep learning algorithms to generate content such as images, videos, audio, text, and other kinds of media based on certain parameters or conditions. Generative AI has the potential to create unique content from scratch without any external input and can be used in various applications such as facial recognition, natural language processing...

Read more

On March 23, 2023, the European Commission published a proposal for a Directive on substantiation and communication of explicit environmental claims ("Green Claims Directive"). This proposal aims to tackle so-called greenwashing claims by regulating how companies communicate and substantiate voluntary environmental claims. Scope The proposal will regulate voluntary environmental claims and environmental labeling provided by traders in business-to-consumer commercial practices. The notion of "environmental claims" is broadly defined and covers any message or representation, including text, pictorial, graphic or symbolic representation, in...

Read more

An unintended consequence of the Tax Cuts and Jobs Act passed during the Trump Presidency is that far more tax filers are now required to file Form 5471; this includes nearly all of TABS’s clients with overseas parents. The Internal Revenue Code previously only required a U.S. taxpayer who owned a certain portion of a controlled foreign corporation (“CFC”) to file Form 5471 – the form’s title is Information Return of U.S. Person with Respect to Certain Foreign Corporations. This was...

Read more

After years of debate, discussion and indecision over income gaps, some states have proposed laws to tax the uber-rich even as President Biden calls for the same. Is America ready to cross this major threshold of taxation? The U.S. may or may not eventually tax the wealthy – but some states aren’t waiting to see. Wealth tax proposals have been put forward – with varying success, observers say – in California, Connecticut, Hawaii, Illinois, Maryland, New York and Washington. Other states...

Read more