International Tax Law Posts

An Overview of the Civil and Criminal Statute of Limitations For Undisclosed Foreign Financial Assets and Unreported Foreign Income

How the Deemed Royalty Regime for Intellectual Property Operates in Cross-Border Transactions

U.S. Tax Planning for Foreigners Intending to own U.S Real Estate

Minimizing U.S. Tax Consequences of U.S. Citizens and Residents Working Overseas

Can a “Multi-Tiered Blocker Structure” be Used to Avoid FIRPTA

A Deep Dive Into the U.S. Tax Consequences of Foreign Investors Holding Domestic Real Estate

Thinking About Renouncing Your Citizenship if Your Presidential Candidate Does Not Win the Election? Here is What You Need to Know About the Expatriation Tax

The Impact of a Section 338 Election to CFC Shareholders

Why Domesticate or Decant a Foreign Non-Grantor Trust

The Difficulties of Portfolio Interest Exemption Planning After the Repeal of Section 958(b)(4)