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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
Blog
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Business and Corporate Tax
Criminal Tax
Cryptocurrency
Estate and Gift Tax
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Offshore Accounts
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Form 5471 Schedule J PTEP Reporting Explained
‘Blocker’ Corporation Considerations for Self-Directed IRA Investors
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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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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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2598 E. Sunrise Blvd. Suite 2104
Fort Lauderdale, FL 33304
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Recent Posts
‘Blocker’ Corporation Considerations for Self-Directed IRA Investors
June 9, 2026 | Anthony Diosdi
For a variety of reasons, self-directed individual retirement account (“IRA”) holders transfer assets to a self-directed Rot…
Read more
The Top Three IRS Defenses to Section 7508A Pandemic Postponement
June 3, 2026 | Anthony Diosdi
There has been a lot of talk about how the Internal Revenue Service (“IRS”) tax deadlines accidentally got turned off for th…
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How Do I Get a U.S. Residency Certificate?
May 17, 2026 | Anthony Diosdi
U.S. individuals and companies that operate internally in a foreign country could be subject to withholding taxes in the for…
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How SDIRA SPVS Can Value Pre-IPO Companies Such as SpaceX, OpenAI, or xAI
May 17, 2026 | Anthony Diosdi
Currently, the top pre-Initial Public Offering (“IPO”) companies based on valuation, growth, and market activity are SpaceX…
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Section 482: Intercompany Agreement Considerations
May 7, 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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FIRPTA and Transfers Between Mixed Status Spouses
April 24, 2026 | Anthony Diosdi
Generally, no income tax is recognized in a transfer of property between spouses (or former spouses) incident to divorce if…
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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…
Read more
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…
Read more
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…
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Tax Planning
Criminal Tax
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