Cross-Border Information Reporting & Civil Penalities (in a Nutshell)

The Internal Revenue Code ("the Code") generally imposes an income tax reporting requirement on all U.S. persons and certain foreign persons with sufficient nexus to the United States. The rules that govern a taxpayer's obligation to fi le a tax return and pay taxes in the United States are exceedingly complex. For the individual income tax return, taxpayers annually spend enormous amounts of time collecting and compiling relevant fi nancial information and determining how best to complete the return.