Frantz Ward Partner Matthew Kadish quoted in "What's Reasonable for Late-Filed Foreign Information Returns" published in Tax Notes Federal, Volume 171 (June 7, 2021)
..."Changing rules retroactively and issuing penalties without meaningful review of submitted statements undermines the confidence of taxpayers and advisers," said Matthew F. Kadish of Frantz Ward LLP. He said that while computerized processing of delinquent international information returns might initially save IRS time, the result might be taxpayers who simply choose not to come forward, or instead simply file outside the delinquent international information return submission procedures, which it now appears effectively ensure a penalty will be asserted...
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