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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
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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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Fort Lauderdale, FL 33304
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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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Recent Posts
Form 5471 Schedule J PTEP Reporting Explained
June 9, 2026 | Anthony Diosdi
Anyone who wishes to complete Schedule J for Form 5471 must understand the basketing and ordering rules of Internal Revenue…
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Live Happily Ever After With A Properly Structured Roth IRA Conversion
May 12, 2026 | Anthony Diosdi
For a variety of reasons, self-directed individual retirement account (“IRA”) holders transfer assets to a self-directed Rot…
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A Deep Dive Into the Anti-Hybrid and Anti-Conduit Regulations
May 7, 2026 | Anthony Diosdi
The Tax Cuts and Jobs Act introduced two Internal Revenue Code provisions targeting “hybrid arrangements.” The provisions in…
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Tax Shelter Litigation and the Importance of Relevancy
April 24, 2026 | Anthony Diosdi
In 2010, Congress codified the economic substance doctrine in Section 7701 of the Internal Revenue Code. The economic substa…
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Is Regulation 301.7508A-1(f) Example 5 the Next Chapter in Section 7508A Tax Litigation?
April 24, 2026 | Anthony Diosdi
There has been a lot of discussion lately regarding Section 7508A in the context of the COVID-19 pandemic and Internal Reven…
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Can U.S. Taxpayers Claim Foreign Tax Credits Against NIIT on Capital Gains?
March 5, 2026 | Anthony Diosdi
Treasury Regulations Section 1.1411-1(e) states that no foreign tax credits are permitted to offset Net Investment Income Ta…
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The United States-Canada Income Tax Treaty 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…
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The IRS Form 5472 Explained in Detail
February 27, 2026 | Anthony Diosdi
The Form 5472 is a mandatory return that must be filed with the Internal Revenue Service (“IRS”) for reportable transactions…
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A Comprehensive Guide of the IRS Form 3520-A
February 26, 2026 | Anthony Diosdi
United States persons with foreign assets are subject to an ever expanding universe of reporting requirements. A prime examp…
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The IRS Form 3520: A Comprehensive Guide
February 26, 2026 | Anthony Diosdi
In general, U.S. persons must file a Form 3520 if: 1) a reportable event occurred during the tax year; 2) a U.S. person tran…
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