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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
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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
Is Section 7508A the Ultimate Defense to IRS Interest and Penalties?
February 27, 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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Demystifying Form 5471 Schedule E and E-1 Used to Report and Track Foreign Tax Credits of Controlled Foreign Corporations
February 20, 2025 | Anthony Diosdi
Form 5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations) is used by certain U.S. persons…
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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…
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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…
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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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