Penalty for failing to file information returns on certain outbound transfers of property substantially expanded.: An article from: The Tax Adviser

This digital document is an article from The Tax Adviser, published by American Institute of CPA's on March 1, 1997. The length of the article is 1092 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: IRC section 1494(c), added under the Small Business Job Protection Act's foreign trust laws, applies a 35% penalty on transfers to foreign entities that are not reported to the IRS on form 926 in a timely fashion. The penalty is 35% of the gross value, not the gain inherent to the property. The penalty may apply even when section 1491 does not apply and when no excise tax is due. The legislative history suggests that Congress did not intend that the provisions be so broadly applicable.

Citation Details
Title: Penalty for failing to file information returns on certain outbound transfers of property substantially expanded.
Author: Bruce Reynolds
Publication:The Tax Adviser (Magazine/Journal)
Date: March 1, 1997
Publisher: American Institute of CPA's
Volume: 28 Issue: n3 Page: 151(2)

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