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Anthony Diosdi
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DIOSDI & LIU, LLP
SF Tax Counsel.
Home
Attorneys
Anthony Diosdi
Partner
Kerrin Liu
Partner
Attorneys
View All Attorneys
Anthony Diosdi
Kerrin Liu
About
Practice Areas
Tax Audits, Controversies, and Litigation
International Penalties
Tax Planning and Opinions
International Tax Planning and Advice
Cross-Border Mergers and Acquisitions
Tax-Exempt and Nonprofit Organizations
Independent Contractor Disputes
Criminal Tax Representation
Cryptocurrency Tax Matters
Tax Preparation
IRS Representation and Compliance
Estate Tax Planning
Estate and Gift Tax for Foreign Investors
Expatriation
Tax Planning of Cross-Border Cloud Computing Transactions
FIRPTA
Tax Preparation of Form 5471
Taxation of Foreign Pensions
FBAR Preparation and Penalty Defense
Preparation of Form 5472
Commercial Litigation
State Tax Planning and Litigation
IRS Offshore Voluntary Disclosure Representation
Preparation of Form 8621 and PFIC Reporting
Practice Areas
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Tax Audits, Controversies, and Litigation
International Penalties
Tax Planning and Opinions
International Tax Planning and Advice
Cross-Border Mergers and Acquisitions
Tax-Exempt and Nonprofit Organizations
Independent Contractor Disputes
Criminal Tax Representation
Cryptocurrency Tax Matters
Tax Preparation
IRS Representation and Compliance
Estate Tax Planning
Estate and Gift Tax for Foreign Investors
Expatriation
Tax Planning of Cross-Border Cloud Computing Transactions
FIRPTA
Recognition
Publications
Speeches
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That’s Crummey! A Closer Look at Crummey Trusts and How they Work
The Limitations Placed on Hybrid Entity Tax Planning
Can a SDIRA Avoid the PFIC?
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505 Montgomery St. 11th Floor
San Francisco, CA 94111
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4900 Hopyard Rd. Suite #100
Pleasanton, CA 94588
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Fort Lauderdale, FL 33304
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505 Montgomery St. 11th Floor
San Francisco, CA 94111
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Pleasanton
4900 Hopyard Rd. Suite #100
Pleasanton, CA 94588
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2598 E. Sunrise Blvd. Suite 2104
Fort Lauderdale, FL 33304
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Recent Posts
That’s Crummey! A Closer Look at Crummey Trusts and How they Work
September 2, 2026 | Anthony Diosdi
Section 2501(a)(1) of the Internal Revenue Code imposes a tax on “the transfer of property by gifts.” Section 2501 specifies…
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The Limitations Placed on Hybrid Entity Tax Planning
September 2, 2026 | Anthony Diosdi
Multinational corporations investing in the United States often rely on U.S. income tax treaties to reduce or eliminate the…
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Can a SDIRA Avoid the PFIC?
August 30, 2026 | Anthony Diosdi
A self-directed IRA or (“SDIRA”) has the ability to invest in private equity and startup-style investments. A SDIRA can also…
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Should a SDIRA Be Used to Obtain a Portugal Golden Visa?
August 30, 2026 | Anthony Diosdi
The Portugal Golden Visa is a unique EU residency-by-investment solution that offers a pathway to Portuguese citizenship wit…
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U.S. Tax Considerations of Foreign Stock Option Plans
August 25, 2026 | Anthony Diosdi
With globalization, more and more Americans are working abroad and participating in foreign stock option plans. Americans ar…
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A Closer Look at Inbound Type F Reorganizations
August 25, 2026 | Anthony Diosdi
Certain publicly traded foreign corporations have recently considered the possibility of “migrating” to the U.S. for various…
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Multinational Corporate Planning Options for the Downward Attribution Rules
August 20, 2026 | Anthony Diosdi
Section 958 of the Internal Revenue Code is an operative provision that provides constructive ownership rules. These constru…
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The Rise of Type F Reorganizations: Key Tax Considerations for Domestication of Foreign Corporations
August 11, 2026 | Anthony Diosdi
Certain publicly traded foreign corporations have recently considered the possibility of “migrating” to the U.S. for various…
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U.S. Taxation of ISOs and NQSOs Held in Foreign Retirement Plans
August 11, 2026 | Anthony Diosdi
With globalization, more and more Americans are working abroad and participating in foreign stock option plans. Americans ar…
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How the OBBBA Modified the CFC Pro Rata Share Rules
August 6, 2026 | Anthony Diosdi
On July 4, 2025, the “One Big Beautiful Bill Act” (“OBBBA”) became law. The OBBBA made significant changes to a number of in…
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Tax Planning
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