Freeman Law

On today's Freeman Law Insights blog, Micah Miller explains accredited investors and their importance to U.S. companies.

Read Micah's full post at https://buff.ly/3KBRB3t.

Accredited Investor Status in Federal Securities Law An accredited investor is a person to whom companies can sell securities in an offering that is not registered with the SEC.

On today's Freeman Law Insights blog, Matthew Roberts discusses a recent Tax Court memorandum opinion in Fairbank and emphasizes the importance of filing timely and complete foreign information returns with the IRS.

Read Matthew's full post at https://buff.ly/3mmVXBV.

Taxpayers’ Failure to File Form 3520 and Form 3520-A Results in Extended Statute of Limitations Period: the Cautionary Tale of Fairbank The IRS disagreed, contending instead that because Mrs. Fairbank had reportable interests in a foreign trust and did not file appropriate information returns (Forms 3520 and 3520-A) that the general three-year statute of limitations period did not apply.

On today's Freeman Law Insights blog, Matthew Roberts discusses a recent Order from the Southern District of California highlighting that the United States must show various other requirements outside the willful context when imposing FBAR penalties.

Read Matthew's full post at https://buff.ly/3IjkOh6.

Does a Treaty Govern FBAR Reporting Obligations: A Federal Court Answers “Yes” A tax treaty between the United States and Mexico could serve to abrogate the definition of a “United States person” under the FBAR-reporting rules.