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 90 days (USD 50,000 maximum). International practice units are developed by the Large Business and International Division of...