Zhanna Ziering Quoted in Tax Notes on Form 5471 Obligations
Tax Analysts’ Freedom of Information Act litigation has revealed the conclusion of a heavily redacted 2022 IRS memorandum, which says that a dual resident relying on a treaty tiebreaker rule can’t dodge information reporting obligations. Zhanna Ziering quoted in Tax Notes article titled Dual Resident Can’t Escape Form 5471 Obligations, Memo Says.