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DIOSDI & LIU, LLP
SF Tax Counsel.
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Anthony Diosdi
Kerrin Liu
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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
Blog
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Business and Corporate Tax
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Cryptocurrency
Estate and Gift Tax
International Tax Law
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Can U.S. Taxpayers Claim Foreign Tax Credits Against NIIT on Capital Gains?
FIRPTA Rules Explained
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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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Locations
San Francisco
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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Fort Lauderdale
2598 E. Sunrise Blvd. Suite 2104
Fort Lauderdale, FL 33304
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Recent Posts
FIRPTA Rules Explained
March 5, 2026 | Anthony Diosdi
U.S. real estate has become a popular investment with foreigners. However, few foreign investors fail to consider the U.S. t…
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The United States-Cyprus Tax Treaty and Its Unusual LOB Explained
March 3, 2026 | Anthony Diosdi
The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions o…
Read more
An Overview of the Rules Governing Intercompany Transactions Involving Intangibles for Multinational Corporations
February 20, 2026 | Anthony Diosdi
Transfer pricing for intangibles between related entities requires arm’s-length rates or transfer prices for patents, tradem…
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The United States- People’s Republic of China Income Tax Treaty Explained
February 17, 2026 | Anthony Diosdi
The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions o…
Read more
OBBA Giveth and Taketh Away Section 958(b)(4) Downward Attribution Rules
February 9, 2026 | Anthony Diosdi
Section 951B was recently enacted by the One Big Beautiful Bill Act (“OBBA”). Section 951B establishes a parallel tax and re…
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How Cryptocurrency Mining Through a Self-Directed IRA are Taxed
February 5, 2026 | Anthony Diosdi
The appeal of investing retirement funds outside of the typical investments has driven a surge in the use of self-directed I…
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Foreign-To-Foreign Mergers and Reorganizations Explained
January 30, 2026 | Anthony Diosdi
In response to changing business conditions, foreign corporations owned by U.S. shareholders routinely merge or reorganize w…
Read more
Can Inverting Corporations Use a Foreign Partnership to Avoid the Anti-Inversion Rules?
January 30, 2026 | Anthony Diosdi
On March 4, 2023, Congress enacted Section 7874 of the Internal Revenue Code to combat the practice of “inverting” a U.S. co…
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Britney Spears Goes to Tax Court: How is a Tax Court Case Litigated and What Can Britney Spears Expect
January 20, 2026 | Anthony Diosdi
Britney Spears recently petitioned the United States to contest a $721,000 IRS proposed assessment related to an S-corporati…
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What George Clooney and Americans Residing in France Need to Know About French Succession and Tax Laws
January 20, 2026 | Anthony Diosdi
Recently, George Clooney, Amal Clooney and their 7-year old twins were granted French citizenship. The granting of French ci…
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Tax Planning
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Business and Corporate Tax
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