IRS Releases Practice Units on Hedge Funds and Penalties for Failing to Timely File Return on Interests in Foreign Partnerships

On 14 February 2017, the U.S. IRS published two international practice units:

• Hedge Fund Basics, which discusses typical hedge fund structures with a focus on tax issues related to a master fund; and
• Monetary Penalties for Failure to Timely File a Complete and Accurate Form 8865 – Category 1 & 2 Filers, which discusses the penalties related to filing Form 8865, which include an initial penalty of USD 10,000, increased by USD 10,000 per 30-day period if failure continues for more than 9…