IRS May Reject Frivolous Tax Arguments and Certain Incomplete Ruling Requests The IRS has procedures in place to prevent taxpayers from delaying tax administration through frivolous arguments or incomplete requests. Depending on the type of IRS proceeding, a submission may be rejected without receiving the full administrative review that taxpayers normally expect. Understanding these rules...

U.S. Trade or Business Determinations Depend on the Facts for Foreign Taxpayers For foreign businesses and investors, one of the most important U.S. tax questions is whether their activities rise to the level of a U.S. trade or business. The answer can significantly affect how income is taxed and whether U.S. filing and withholding obligations...

IRS Clarifies Portfolio Interest Tax Rules for Foreign Investors The portfolio interest exemption is an important tax benefit that allows many foreign investors to receive certain U.S.-source interest income without being subject to U.S. withholding tax. However, not every foreign investor automatically qualifies. The IRS has provided additional guidance on how eligibility is determined, particularly...

IRS Applies Strict Standards for Reasonable Cause Penalty Relief Receiving an IRS penalty does not automatically mean you have to pay it. In many situations, taxpayers can request penalty relief by showing they had “reasonable cause” for failing to meet a tax obligation. However, the IRS applies strict standards when evaluating these requests, and the...