After reading this article this morning, we as tax professionals really have to be on top of the new rulings that come out. In this article the law had the ability to realize that the company did not owe simply because they were erroneously mislead by their CPA. Very interesting read on how we can educate our foreign investors on the best ways to avoid paying US income taxes when they invest in US Corporations.

https://www.accountingtoday.com/news/tax-court-invalidates-long-standing-irs-ruling-on-taxing-foreign-partners

Taxing Foreign Partners

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