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DIOSDI & LIU, LLP
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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
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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
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How Use a Section 6751(b)(1) Defense in an International Penalty Case
Will Loper-Bright Have Any Impact on Tax Litigation with the IRS?
The IRS Finalizes Regulations for the Section 2801 Inheritance Tax
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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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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
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…
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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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IRS Form 8621 and PFIC Reporting Rules
November 19, 2024 | Anthony Diosdi
This article provides guidance on how to report Passive Foreign Investment Company (“PFIC”) shares on a Form 8621. This arti…
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How is Restitution and the Cost of Prosecution Determined in a Criminal Tax Case
October 1, 2024 | Anthony Diosdi
If you are found guilty or plead guilty in a federal criminal tax case, the court will likely order you to pay restitution…
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Estate Freezing Techniques Available Through Grantor Retained Annuity Trusts
September 27, 2024 | Anthony Diosdi
The United States imposes estate and gift taxes on certain transfers of U.S. situs property by “nonresident citizens of the…
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What Clients and Tax Advisors Can Learn From the Prosecution of John Castro of Castro & Company
August 23, 2024 | Anthony Diosdi
On May 24, 2024, John Castro, the managing partner of Castro & Company was convicted of 33 counts of assisting in the pr…
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Is the Sentencing Guidelines’ Zero-Point Offender Provision a Get Out of Jail Free Card for First-Time Criminal Tax Offenders?
August 16, 2024 | Anthony Diosdi
Under Amendment 821 to the Federal Sentencing Guidelines, the United States Sentencing Commissioner added two new Guidelines…
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The Internal Revenue Service Criminal Investigation Process
August 6, 2024 | Anthony Diosdi
The Internal Revenue Service uses the threat of criminal sanctions, fines, and the possibility of imprisonment to deter no…
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Specific Criminal Sanctions
August 6, 2024 | Anthony Diosdi
An individual or business involved in a criminal tax investigation may ultimately be prosecuted for specific revenue offen…
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Potential Sentence Reduction for Federal Criminal Tax Defendants
July 23, 2024 | Anthony Diosdi
This article provides a brief overview as to how a court determines a sentence after a defendant is convicted of a federal t…
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