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Writing about tax law is our passion. As a matter of fact, few law firms blog more about tax law than us. Our blog is read in every corner of the world. We hope that you will find our blogs informative and insightful.

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Recent Blog Posts

How Does the Fifth Amendment Privilege Against Self-Incrimination Apply in a Criminal Tax Case?

February 14, 2025 | Anthony Diosdi

The Fifth Amendment of the U.S. Constitution provides that “no person … shall be compelled in any criminal case to be a witn…

How Fourth Amendment Can be Utilized to Challenge an IRS Summons

February 14, 2025 | Anthony Diosdi

An individual who is the subject of a criminal tax case has the same rights as any other criminal defendant against unreason…

Is it Possible to Quash an IRS Summons Issued to Build a Civil or Criminal Tax Case in a Foreign Country?

February 14, 2025 | Anthony Diosdi

The rapid rise of globalism has made the world feel smaller. Americans are more connected to people on the other side of the…

How Use a Section 6751(b)(1) Defense in an International Penalty Case

February 5, 2025 | Anthony Diosdi

Chapter 61 of the Internal Revenue Code contains countless reporting requirements regarding foreign information filing oblig…

Will Loper-Bright Have Any Impact on Tax Litigation with the IRS?

January 30, 2025 | Anthony Diosdi

Recently, in Relentless Inc. v. U.S. Department of Commerce and Loper Bright Enterprise v. Raimondo, the Supreme Court overr…

The IRS Finalizes Regulations for the Section 2801 Inheritance Tax

January 30, 2025 | Anthony Diosdi

Anyone considering abandoning their U.S. citizenship or ending a long-term U.S. residency must understand that they may be a…

Are Foreign Cash Gifts Taxable?

January 24, 2025 | Anthony Diosdi

The Tax Cut and Jobs Act of 2017 currently excludes $13.90 million of assets from estate and gift taxes of a U.S. citizen or…

How to Plan for the U.S. Exit Tax

January 24, 2025 | Anthony Diosdi

The number of U.S. citizens and U.S. residents expatriating from the United States has increased at an annual rate of 20 per…

The Benefits of Utilizing Gain Recognition Agreements in Cross-Border Corporate Transfers

January 24, 2025 | Anthony Diosdi

Whenever a U.S. person decides to establish a foreign corporation (or foreign business entity), it will be necessary to capi…

Does the Seventh Amendment Invalidate International Penalties?

January 22, 2025 | Anthony Diosdi

Adjudicatory powers have been a power essential to federal agencies like the Internal Revenue Service (“IRS”), agencies supp…

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