Michael Karlin’s comments regarding the treatment of foreign gifts and the case for reform of Section 6039F, submitted to the IRS on March 3, 2023, have been published in Tax Notes.
In response to the IRS’ Request for Comments on Forms 3520 and 3520-A, Karlin asserts that “...current IRS practice in relation to these forms is abusive and cannot be what was intended (if anything at all was intended) when Section 6039F was enacted.” The inclusion of his article “Poisoned Gifts: The Case for Reform of Section 6039F” in the comments further supports his call for repeal or reform of Section 6039F, which imposes heavy penalties on taxpayers for noncompliance.
Read the comments in Tax Notes, or view the article in PDF below.
