Topic
International Reporting
11 published works
AGP & Co Insights
CySEC Circular C754: ESMA Cross-Border Reporting for Cyprus Investment Firms
CySEC Circular C754: ESMA Cross-Border Reporting for Cyprus Investment Firms Key Obligations and Practical Guidance On 09/02/2026 the Cyprus Securities and Exchange Commission (“CySEC”) issued Circular C754, introducing a new…
Subject to Inquiry
Treasury Department Declares Intent to Limit CTA to Foreign Reporting Companies
By Jeffrey M. Hanna, Lauren Mann
After the Financial Crimes Enforcement Network (FinCEN) stated that it would hold off on taking enforcement actions against Reporting Companies for failure to comply with the March 21, 2025, deadline…
Tax Controversy Report
What’s Next for International Reporting Post-Farhy?
By Meeren Amin
Last April, in Farhy v. Commissioner, the Tax Court held that the IRS did not actually have authority to assess penalties under IRC § 6038. The result was devastating for…
Tax Controversy Report
Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties
By Meeren Amin
In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the taxpayer…
Tax
Tax Court Offshore Penalty Negotiation Trials & IRS Settlement
By Board-Certified Tax Law Specialist, Golding
Tax Court Offshore Penalty Negotiation and Trials Tax Court Offshore Penalty Negotiation Trials & IRS Settlement: The number of Offshore Penalty tax court cases for non-filing or non-compliance with IRS International…
CommLaw Monitor
International Bureau Temporarily Waives Section 43.62 International Traffic and Revenue Reporting Requirement
By Denise Smith
By an International Bureau (Bureau) Order (Order) released yesterday that temporarily waives the International Traffic and Revenue Reporting (the Traffic and Revenue Report) requirement, the Federal Communications Commission (FCC) appears to…
CommLaw Monitor
Comment Deadlines Set for FCC’s Latest International Reporting Streamlining Rulemaking
By Denise Smith
As Kelley Drye reported in a post late last month, the Federal Communications Commission (FCC) is considering eliminating the FCC Rule 43.62(b) annual International Traffic and Revenue reporting obligation and…
CommLaw Monitor
Special Deadline Set for Section 43.62 International Traffic and Revenue Reports Filed in 2015
By Chip Yorkgitis, Denise Smith
The FCC announced on Friday, August 7, 2015, that the deadline for affected carriers and providers to file their annual international traffic and revenue reports this year -- postponed from…
CommLaw Monitor
FCC Announces Effectiveness of New International Reporting Requirements, Deadline for Filing Uncertain
By Chip Yorkgitis, Denise Smith
In January 2013, the Federal Communications Commission (“FCC”) comprehensively revised its reporting rules applicable to providers of international telecommunications, making numerous substantive revisions to the categories of providers subject to…
CommLaw Monitor
FCC Proposes Rare Fine for Failure to File Section 43.61 International Traffic and Revenue Reports
By Kelley Drye
On December 6, 2013, the FCC issued a rare Notice of Apparent Liability for Forfeiture, against Start Wireless Group, Inc. d/b/a Page Plus Cellular (“Page Plus”), for failing to file…