Megan L. Brackney and Joseph Septimus published in the WG&L Journal of International Taxation, "How Foreign Corps. That Miss a Filing Can Avoid Losing U.S. Tax Deductions"

By Megan Brackney

The Regulations provide that the IRS may waive the filing deadline and, therefore, allow a foreign corporation that missed a deadline to use its deductions and credits if the corporation "acted reasonably and in good faith."

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