D.C. Circuit reverses Tax Court on assessment of foreign entity ownership reporting penalties.

The article focuses on the D.C. Circuit's ruling that the Internal Revenue Service (IRS) has the authority to assess penalties for failing to report foreign entity ownership under Section 6038(b), despite the Tax Court's prior decision. Topics include the IRS's authority to assess and collect these penalties administratively; the arguments presented by the taxpayer and the IRS regarding the interpretation of tax laws; and the implications of the court's decision for tax enforcement practices.