San Francisco Tax Blogs | Diosdi, Ching, & Liu, LLP

02Nov 2021 by Anthony Diosdi

The Immigration Consequences Counsel Should Understand When Representing a Noncitizen Who is Criminally Prosecuted for Failing to Disclose Foreign Income or Foreign Bank Accounts

Tax Law

By Anthony Diosdi The Internal Revenue Service (“IRS”) has been on a hiring spree and is gearing up for a major offensive. There has been a lot of saber rattling coming from the IRS that in the near future there will be a dramatic increase in referrals for criminal prosecution. One area that is always a favorite of the IRS is to go after undisclosed foreign bank accounts and reported foreign income. One group that may be hit particularly by an increase in prosecutions of unreported fotreign income or foreign bank accounts are noncitizens such as green card holders. This article discusses the immigration consequences a nonresident could face if he or she is charged with a tax crime or crimes associated for failing to disclose foreign income and foreign…

26Oct 2021 by Anthony Diosdi

Unraveling the United States- Australia Income Tax Treaty and How Australian Nationals with Superannuation Funds, 401(k) Plans, IRAs, and 403(a) Plans can Benefit From the Treaty

Tax Law

By Anthony Diosdi The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types of income derived by residents of one treaty country from sources within the other treaty country. Because tax treaties often substantially modify U.S. and foreign tax consequences, the relevant treaty must be considered in order to fully analyze the income tax consequences of any outbound or inbound transaction. The U.S. currently has income tax treaties with approximately 58 countries. This article discusses the implications of the United States- Australia Income Tax Treaty. There are several basic treaty provisions, such as permanent establishment provisions and reduced withholding tax rates, that are common to most of the income tax treaties to which the United States is a…

26Oct 2021 by Anthony Diosdi

Unraveling the United States- Israel Income Tax Treaty

Tax Law

By Anthony Diosdi The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types of income derived by residents of one treaty country from sources within the other treaty country. Because tax treaties often substantially modify U.S. and foreign tax consequences, the relevant treaty must be considered in order to fully analyze the income tax consequences of any outbound or inbound transaction. The U.S. currently has income tax treaties with approximately 58 countries. This article discusses the implications of the United States- Israel Income Tax Treaty. There are several basic treaty provisions, such as permanent establishment provisions and reduced withholding tax rates, that are common to most of the income tax treaties to which the United States is a…

18Oct 2021 by Anthony Diosdi

Unraveling the United States- Italy Income Tax Treaty and a Closer Look as to How the Treaty Views Fiscally Transparent Entities Such as “Hybrid” and “Reverse Hybrid” Entities

Tax Law

By Anthony Diosdi The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types of income derived by residents of one treaty country from sources within the other treaty country. Because tax treaties often substantially modify U.S. and foreign tax consequences, the relevant treaty must be considered in order to fully analyze the income tax consequences of any outbound or inbound transaction. The U.S. currently has income tax treaties with approximately 58 countries. This article discusses the implications of the United States- Italy Income Tax Treaty. There are several basic treaty provisions, such as permanent establishment provisions and reduced withholding tax rates, that are common to most of the income tax treaties to which the United States is a…

18Oct 2021 by Anthony Diosdi

Did You Get an Audit Notice?

Tax Law

Most people assume that an audit will never happen to them. After all, they are honest on their taxes and pay what they should, so why would they be audited? But then, a notice of audit arrives in the mail, and you start to wonder whether you made mistakes on your taxes that can get you in trouble. What is the best course of action in this situation? Contact a Tax Attorney First, you should always consult with a San Francisco tax lawyer if you receive notice that you will be audited. We can review the returns in question, as well as all communications from the IRS. We can assist you in gathering and submitting all of the necessary information and documentation to the auditor. When an attorney helps you…

07Oct 2021 by Anthony Diosdi

Unraveling the United States- Ireland Income Tax Treaty

Tax Law

By Anthony Diosdi The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types of income derived by residents of one treaty country from sources within the other treaty country. Because tax treaties often substantially modify U.S. and foreign tax consequences, the relevant treaty must be considered in order to fully analyze the income tax consequences of any outbound or inbound transaction. The U.S. currently has income tax treaties with approximately 58 countries. This article discusses the implications of the United States- Ireland Income Tax Treaty. There are several basic treaty provisions, such as permanent establishment provisions and reduced withholding tax rates, that are common to most of the income tax treaties to which the United States is a…

07Oct 2021 by Anthony Diosdi

Unraveling the United States- Mexico Income Tax Treaty

Tax Law

By Anthony Diosdi The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types of income derived by residents of one treaty country from sources within the other treaty country. Because tax treaties often substantially modify U.S. and foreign tax consequences, the relevant treaty must be considered in order to fully analyze the income tax consequences of any outbound or inbound transaction. The U.S. currently has income tax treaties with approximately 58 countries. This article discusses the implications of the United States- Mexico Income Tax Treaty. There are several basic treaty provisions, such as permanent establishment provisions and reduced withholding tax rates, that are common to most of the income tax treaties to which the United States is a…

05Oct 2021 by Anthony Diosdi

Business Impact of the United States- France Income Tax Treaty

Tax Law

By Anthony Diosdi The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types of income derived by residents of one treaty country from sources within the other treaty country. Because tax treaties often substantially modify U.S. and foreign tax consequences, the relevant treaty must be considered in order to fully analyze the income tax consequences of any outbound or inbound transaction. The U.S. currently has income tax treaties with approximately 58 countries. This article discusses the implications of the United States- France Income Tax Treaty. There are several basic treaty provisions, such as permanent establishment provisions and reduced withholding tax rates, that are common to most of the income tax treaties to which the United States is a…

05Oct 2021 by Anthony Diosdi

Unraveling the United States- India Income Tax Treaty

Tax Law

By Anthony Diosdi The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types of income derived by residents of one treaty country from sources within the other treaty country. Because tax treaties often substantially modify U.S. and foreign tax consequences, the relevant treaty must be considered in order to fully analyze the income tax consequences of any outbound or inbound transaction. The U.S. currently has income tax treaties with approximately 58 countries. This article discusses the implications of the United States- India Income Tax Treaty. There are several basic treaty provisions, such as permanent establishment provisions and reduced withholding tax rates, that are common to most of the income tax treaties to which the United States is a…

29Sep 2021 by Anthony Diosdi

Unraveling the Controversial United States- Hungary Income Tax Treaty

Tax Law

By Anthony Diosdi The major purpose of an income tax treaty is to mitigate international double taxation through tax reduction or exemptions on certain types of income derived by residents of one treaty country from sources within the other treaty country. Because tax treaties often substantially modify United States and foreign tax consequences, the relevant treaty must be considered in order to fully analyze the income tax consequences of any outbound or inbound transaction. The United States currently has income tax treaties with approximately 58 countries. This article discusses the highly controversial United States- Hungary Income Tax Treaty. There are several basic treaty provisions, such as permanent establishment provisions and reduced withholding tax rates, that are common to most of the income tax treaties to which the U.S. is a…