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Recent Posts

How the Anti-Inversion Rules Tax Expatriating Corporations

January 8, 2026 | Anthony Diosdi

Over the years there has been a number of high profile corporate inversions. However, recent tax law changes have significan…

Is a SAFE a “safe” Planning Option for the Anti-Inversion Rules?

December 11, 2025 | Anthony Diosdi

Congress has enacted various provisions to tax shareholders who transfer appreciated shares of U.S. corporations for shares…

What Foreign Investors Need to Know About Estate Planning and Treaties

December 11, 2025 | Anthony Diosdi

Foreign investors generally have the same goal of minimizing their tax liabilities from their U.S. real estate and other U.S…

Does the IRS Have the Authority to Assess International Penalties Associated with Form 5472?

November 12, 2025 | Anthony Diosdi

Recently, in Farhy v. Commissioner, 160 T.C. No. 6 (2023), the United States Tax Court determined that the Internal Revenue…

How to Substantiate a Foreign Tax Credit

November 4, 2025 | Anthony Diosdi

Under Section 901(b)(1) of the Internal Revenue Code, U.S. citizens and U.S. corporations are entitled to a foreign tax cred…

Can Partners of Law Firms be Treated as Employees for Employment Tax Purposes?

November 4, 2025 | Anthony Diosdi

Partners of law firms are typically treated as independent contractors for income tax purposes because they are considered s…

Potential U.S. Tax Consequences for Foreign App Developers that Utilize U.S. Platforms to Sell Apps to Customers

October 27, 2025 | Anthony Diosdi

On January 14, 2025, the Internal Revenue Service (“IRS”) and the Department of Treasury made significant changes to the dig…

Can Foreign Withholding Tax on Patent Infringement Damages Qualify for a Foreign Tax Credit?

October 27, 2025 | Anthony Diosdi

There has been an increase in cross-border patent litigation that has been driven by the globalization of innovation. These…

The Foreign Tax Credit Explained

October 27, 2025 | Anthony Diosdi

U.S. taxpayers are generally subject to U.S. tax on their worldwide income, but may be provided a tax credit for foreign tax…

Something Old, Something New … Self-Directed IRA Planning in the 21st Century

October 23, 2025 | Anthony Diosdi

Since 1974, the IRS has permitted individuals to totally “self-direct” investments made within their Individual Retirement P…

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