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Beware of the Pitfalls of Rental Property Tax Laws
What You Need to Know About OVDP After September 28, 2018
Can You “DING” Your State Tax Liability With a “NING,” “WING,” or “SDING”?
A Landmark Decision Recently Decided by the Supreme Court Regarding Sales Tax may Affect eCommerce Sellers
Five Tax Traps That All Non Residents Coming to The United States Must Know
Buyer Beware: The Basic Rules Governing FIRPTA Withholding on Real Estate
The IRS Announces the 2018 Offshore Voluntary Disclosure Program
Beware of Investing in Conservation Easements Offered by Promoters of Easement Syndicates
It’s Not Your Father’s Retirement Account Anymore- The Basics of Using a Self-Directed IRA and 401Ks to Invest in Real Estate
A New Anti-Deferral for International Taxation has Been Announced, Don’t be Guilty of Owing the GILTI Tax
GILTI vs. FDII: Outbound International Taxation Showdown
Criminal Aspects of Failing to Disclose Foreign Financial Accounts
GILTI as Charged? Maybe 962 Can Bail You Out
Demystifying the Taxation of Deferred Foreign Earnings
Just in Time for Tax Season: Change to IRS Form 5471
“BEAT” Again- The New BEAT Tax Regime Considerations and Compliance Requirements Imposed on U.S. Inbound Transactions Involving Foreign Corporate Parents
The General Treaty Provisions That All Individual Foreign Investors Should Consider Before Investing in the United States
Should You Hire an Attorney for Your Business Tax Preparation in 2019?
The U.S. Tax Effects of Entities Used by Foreign Investors
A Closer Look at the Non-Willful FBAR Penalty Associated with Not Timely Filing a FinCen Report 114
Reporting Requirements for U.S. Persons Who Receive Large Gifts From Foreign Persons
Did You Receive a Notice CP 508C From the IRS Stating That Your Passport is Being Revoked? Maybe the APA Can Prevent the IRS from Taking Your Passport
Income Tax Considerations of Property Inherited from A Foreign Person
The Branch Profits Tax and the Foreign Corporation
Establishing a Residency Termination Date For Tax Planning Purposes
The U.S. Withholding Tax on a Foreign Partner’s Share of Effectively Connected Taxable Income
Tax Planning for Foreign Individuals That Own U.S. Real Property
U.S. Real Property Interest Non-Recognition Transfers- Can the Internal Revenue Service Assess Interest When No Tax is Due?
Transfer of Property Between Spouses During Divorce When the Transferee Spouse is a Nonresident Alien
Violation of a Temporary Visa and the Possible Effect on “Domicile”
Discrepancy of the U.S. Income Tax Consequences for Foreign Investors Selling Limited Liability Company Units Compared to Corporate Shares
The Impact of an Installment Sale and the Potential Branch Profits Tax Liability for any Foreign Corporation Doing Business in the U.S.
Can a Non-U.S. Citizen/Non-Domiciliary be Subject to a U.S. Gift Tax for Gifting Money to a U.S. Family Member?
The Perils of a Foreign Individual Transferring U.S. Real Property for No Value
The Potential Adverse Consequences Associated with the Transfer of Property to Foreign Entities by U.S. Persons
Can Non-U.S. Citizens Elect to be Taxed as an “S” Corporation?
Are Prosecutors Making a Mistake by Prosecuting Lori Loughlin For Honest Services Wire Fraud?
Does Lori Loughlin Have an “Ignorance of the Law” a Defense to a Charge of Money Laundering? By Anthony Diosdi
Want to Contest Penalties Associated with Forms 5471 or 3520 before the Tax Court? Think Twice About Requesting an IRS Appeals Conference.
The Deductibility Fines and Penalties Has Gotten Easier Thanks to the First Circuit Court of Appeals
Working Outside the United States? You Can Potentially Exclude $105,900 from Federal Income Taxation
The Tax Deferral Afforded by an Interest-Charge DISC should be Considered by any Export Company
Is it Possible to Obtain a Refund of the OVDP Offshore Penalty
The Taxation of Passive Foreign Investment Company (“PFIC”): The Use of a Sledgehammer to Kill a Cockroach
Foreign Tax Credit Planning- The Use of the “Technical Taxpayer” Rule to Split Foreign Tax Credits
Renouncing a U.S. Citizenship for Tax Purposes- Breaking Up is Hard to Do
Just How Can I Obtain an Identification Number or ITIN
A Brief Discussion of the New Business Interest Expense Limitation Rules
Can a Representative of an Estate be Forced to Defend Against an FBAR Penalty in Court?
Is Constructive Knowledge Enough to Assess a Willful FBAR Penalty?
Is the APA Still Relevant in FBAR Penalty Litigation?
The “Nuts and Bolts” of Contesting an FBAR Penalty Through Either the Tucker Act or Little Tucker Act
Time’s Up: Tolling Events That Extend the IRS’ Ability to Collect on You
Facing an FBAR Penalty? Better Make Sure Your Attorney Understands Administrative Law
The IRS’ Own Regulation is Successfully Used Against them in Two Willful FBAR Penalty Cases
Cryptocurrency and Taxes
Making a Voluntary Disclosure to the IRS- Everything You Wanted to Know But Were Afraid to Ask
What is the Streamlined Filing Compliance Procedures
Does an Individual Holding Cryptocurrencies on a Foreign Exchange Have a Legal Obligation to Disclose that Interest on an FBAR or Form 8938
About to Disclose a Previously Undisclosed Foreign Financial Asset to the IRS through the OVDP or Streamlined Filing Compliance Procedures? Better Learn About Option 4
The Basics of Claiming a Section 199A Deduction and a Potential Alternative
A Quick Look at The Investment in a Qualified Opportunity Fund Rules
How a Nonresident Can Utilize the Closer Connection Test or a Treaty Tie-Breaker Provision to Avoid Being Taxed as a U.S. Resident
PFICs and the Statute of Limitations- Finally Some Good News
What is an Offer in Compromise?
There May By 50 Ways To Leave Your Lover But Only 1 Way To Make a Transfer To a “Ding,” NING,” “WING,” Or “SDING”
Failed to Disclose a Virtual Currency on Your Tax Return? You May be Receiving Either an “IRS Letter 6173,” “IRS Letter 6174,” or “IRS Letter 6174-A” in the Very Near Future
Conducting Business Abroad? The Check-the-Box Regulations and Cross Border Tax Arbitrage May Offer Significant Tax Savings Opportunities
Part Time Lovers- International Tax Attorneys and the Estate and Gift Tax
Can Todd and Julie Chrisley of “Chrisley Knows Best” Blame their Legal Troubles on a Whistleblower Statute?
No, No, No, No….Prohibited Transactions and Disqualified Persons in Self-Directed IRAs
Can You Live Happily Ever After in California Holding Real Property in a “Tenancy by the Entirety” Form of Ownership?
When Can a Foreign Tax Credit be Claimed?
Be Careful When Receiving a Gift From a Foreign Corporation or Partnership
Don’t Feel GILTI About Paying Only 10.5 Percent Tax On Foreign Source Income
When Can a Foreign Tax Credit be Claimed? Part II. The Changes GILTI Made in the Way Foreign Tax Credits are Calculated
Yes- You Can be Taxed at the Lower Federal C Corporation Rates on Foreign Source Income Without Incorporating or Being Subject to Two Layers of Tax
The IRS Offers Settlements for Owners of Micro-Captives Insurance Companies
What Happens if You Are a Criminal Tax Defendant and Receive a Summons to Appear Before a District Court
Possible Waiver for 2018 Failure to Meet Estimated Tax Obligations
Disagree with an IRS Audit- Here Are Your Options
How is the Branch Profits Tax Calculated?
Bringing a Case Before the United States Tax Court A to Z. Part 1. What is the Significance of Receiving a Notice of Deficiency From the IRS?
Bringing a Case Before the United States Tax Court A to Z Part III. How to Proceed with a Tax Court Trial
Bringing a Case Before the United States Tax Court A to Z Part II. Petitioning the Court, the Appeals Process, and Discovery
Demystifying the IRS Form 5471 Part 1. Selecting the Proper Category of Filer and Preparing Schedule B
Will Your Form 5471 Be Dinged By the IRS’ $10,000 Penalty For Being ‘Substantially Incomplete’?
Demystifying the IRS Form 5471 Part 2. Schedule C
Demystifying the IRS Form 5471 Part 3. Schedule E
Demystifying the IRS Form 5471 Part 4. Schedule J
The Importance of Determining Accurate Earnings and Profits of Foreign Corporations for U.S. Tax Compliance Purposes
The Taxation of Offshore Accumulated Earnings under Section 959- Before and After the 2017 Tax Cuts and Jobs Act
Despite the Enactment of the 2017 Tax Cuts and Jobs Act, the High-Taxed Exception to Subpart F Income Continues to Allow CFC’s to Defer Foreign Income From U.S. Taxation
Demystifying the IRS Form 5471 Part 5. Schedule I-1
Tax Tips for the End of the Year
Tax-Free Spinoffs in the International Tax Context and the Danger of Subpart F Income Inclusion
Inbound Structuring for U.S. Real Estate in a Post-2017 Tax Cut and Jobs World
Owe the IRS? What Can be Done to Prevent IRS Levies or Garnishments
FIRPTA and Partnership Interest Withholding Rules Under the Tax Cuts and Jobs Act
Hovering Deficits- Uncertain Times in Cross Border Mergers with the Enactment of the 2017 Tax Cuts and Jobs Act
All I Want for Christmas is a Refund of the 965 Tax I Overpaid
Attention California Homeowners Age 55+: How Proposition 60/90 Could Benefit You
New Rules Governing Disregarded Entities Owned by Nonresidents Impose Significant New Reporting and Compliance Requirements
Top Four Ways to be Audited by the IRS in 2020
The IRS Continues to Aggressively Audit RaPower3 Investors
New York Estate of Mind
The District Court Allows a Suit to Proceed Challenging the Regulations to Section 965 of the Internal Revenue Code
Demystifying the Form 5471 Part 6. Schedule O
Tax Return Changes for 2020
Should Your LLC be Taxed as a Disregarded Entity or a Corporation?
Is 2020 the New 2018 for Estate, Gift, and Generation-Skipping Tax Purposes?
The IRS Whistleblower Program and the Potential for Additional Recovery Under the False Claims Act
Intentionally Defective Grantor Trusts: Estate Planning with Schrödinger’s Cat
An Overview of the Taxation of Cloud Transactions and Digital Downloads
A Possible Solution to Gift Tax Concerns Associated with Cash, Check, or Wire Transfer Gifts from Overseas
Say it Ain’t So- FATCA Goes Criminal
Are Families Who Took Advantage of the Temporary Increase in the Unified Credit for Estate and Gift Taxation Purposes in for a Very Unpleasant Surprise after 2025?
Are Taxpayers Who Fail to File a FBAR Today at Greater Risk of Being Assessed the Willful ($100,000) FBAR Penalty?
Calculating Foreign Tax Credits Before and After the 2017 Tax Cut and Jobs Act
Your Chance of an IRS Audit is Way Down. But That’s Not Good News if You Have to File an IRS Form 3520 and/or IRS Form 3520-A
Cross-Border Tax Planning with the Proposed Regulations Regarding Cloud Computing Transactions and Digital Downloads
Former Miami Dolphins Linebacker Zach Thomas Will Go Up Against His Toughest Opponent to Date- The IRS in Refund Litigation
Crossing The Line – Felony Tax Crimes
Dynasty Trusts- the Most Powerful Tool Available to Combat the Estate, Gift, and Generation Skipping Taxes
The Collection of State Sales Tax in Today’s eCommerce World
With the Coronavirus on Everyone’s Mind- Now is a Good Time to Consider Medical Expense Tax Deduction Planning
The IRS “Swings for the Fences” and Asserts a $120 Million FBAR Penalty
A District Court Determines that a Sole Beneficiary of a Foreign Trust is Subject to Only a 5 Percent Penalty for the Untimely Filing of IRS Form 3520 and Not the Usual 35 Percent Penalty
What Happens When the IRS Makes an Error?
Advanced Strategies Available to Mitigate the Tax Consequences of GILTI Inclusions
The Trump Administration will Likely Delay the April 15th Tax Filing Deadline in Response to the Coronavirus Outbreak
Does the United States Tax Court have Jurisdiction to Review Penalties Assessed by the IRS for Not Timely filing Form 3520 or 3520-A?
The IRS Has Deferred 2020 Income Tax Payments by 90 Days. What Happens in 90 Days?
Demystifying the Form 5471 Part 7. Schedule P
Relief from Filing Forms 3520 and Form 3520-A for Some
Beware of the New CFC Rules Triggering a Surprise 965 Inclusion
The IRS Delays the Filing Deadline from April 15th to July 15th
Do Shareholders of Dormant Foreign Corporations Still Need to File a Form 5471?
Demystifying the Form 5471 Part 8. Schedule M
As Per the “People First Initiative,” the IRS will Suspend Most Audits and the Collection of Most Back Tax Liabilities
Tax Deadlines for 2020
Demystifying the Form 5471 Part 9. Schedule G
The Nuts and Bolts of the CARES Act Economic Disaster and Payroll Protection Loan Programs
Understanding the Beneficial Rules of the CARES Act for Retirement Fund Withdrawals
Demystifying the Form 5471 Part 10. Schedule I
Introduction to Corporate Cross-Border Transfers, Reorganizations, and Inversions Part 1. The “Toll Charge”
Can a 965 Repatriation or Transition Tax Assessment be Compromised Through an Offer in Compromise?
The Government Begins to Hunt Down Individuals Who Received Commissions and Referral Fees from RaPower-3
Does Section 958 Attribution Rules Impute the Value of Stocks Owned by a Nonresident Spouse to a U.S. Citizen/Resident for Expatriation Tax Purposes?
Introduction to Corporate Cross-Border Transfers, Reorganizations, and Inversions Part 2. “Taxation of Mergers and Acquisitions in Which a Foreign Corporation Acquires a U.S. Corporation”
Demystifying IRS Form 3520
Taxation of Foreign Trust Beneficiaries and a Dive into the “Throwback Tax”
Introduction to Corporate Cross-Border Transfers, Reorganizations, and Inversions Part 4. “U.S. Taxation of Foreign-to-Foreign Acquisitive Reorganizations”
Introduction to Corporate Cross-Border Transfers, Reorganizations, and Inversions Part 3. “The Anti-Inversion Rules- It’s Not Just for Large Multinational Corporations Anymore”
Demystifying IRS Form 3520-A
What to Do if You are Facing a Tax Audit
Can an Item of Foreign Source Income be Double Taxed Under Both the Subpart F and GILTI Rules?
An Overview of Classifying Earnings and Profits Reported on Form 5471 Schedule J Before and After 2017 International Tax Reform
Making a Section 962 Election to Reduce Income Taxes Associated with a GILTI Inclusion? Don’t Forget About the Second Layer of Tax and the Ordering Rules
Schedule J of Form 5471- Preparing the Schedule Before and After International Tax Reform
Demystifying the Form 5471 Part 11. Schedule E-1 Calculating a CFC’s E&P for Purposes of Reporting Foreign Tax Credits
Demystifying the Form 5471 Part 12. Schedule H Calculating the E&P of a Controlled Foreign Corporation
The Top Five Tax Planning Opportunities and Pitfalls that Should be Considered Before Contributing Stock of a CFC to a Holding Corporation to Reduce the U.S. Tax Liability on GILTI
Demystifying the Form 1118 Foreign Tax Credit- Corporations Part 1. Schedule A “Income or (Loss) Before Adjustment”
Reporting Capital Gains
Demystifying the Form 1118 Foreign Tax Credit- Corporations Part 2. Schedule B “Foreign Tax Credit”
Demystifying the Form 1118 Foreign Tax Credit- Corporations Part 3. Schedule C “Tax Deemed Paid With Respect to Section 951(a)(1) Inclusion by Domestic Corporation Filing Return (Section 960(a))”
Demystifying the Form 1118 Foreign Tax Credit- Corporations Part 5. Schedule E Reporting PTEPs of Tiered CFCs
Demystifying the Form 1118 Part 4. Schedule D Foreign Tax Credits Associated with GILTI Inclusions
Demystifying the Form 1118 Part 6. Schedule F-1 Determining the Tax Consequences of Dividends from First-Tier Foreign Corporation and Inclusions of the Earnings of a First or Lower Tier Foreign Corporation Prior to Tax Reform
Demystifying the Form 1118 Part 7. Schedule F-2 Determining the Tax Consequences of Tax Deemed Paid by a First-Foreign Corporation with Respect to Dividends from a Second-Tier Foreign Corporation Prior to Tax Reform
Demystifying the Form 1118 Part 8. Schedule F-3 Determining the Tax Consequences of Tax Deemed Paid by Third, Fourth, and Fifth-Tier Foreign Corporations Under Section 902(b) Prior to Tax Reform
Form 8993 and Claiming the Section 250 Deduction
Demystifying the Form 1118 Part 9. Schedule G Reduction of Taxes Paid, Accrued, or Deemed Paid by a CFC
The IRS Has Yet to Issue Final Regulations for Section 987 Foreign Currency Branch Transactions
The General Rules Governing Currency Conversations for Computing Foreign Tax Credits and the Section 986 Election
Tax Refunds and Chapter 7 Bankruptcy
Understanding the High-Tax Kickout and its Impact on Foreign Tax Credits
Calculating the Foreign Tax Credit and the CFC Netting Rule
Top Audit Triggers of a CFC that Catch the Attention of the IRS. Part One- Calculating a Net Section 965 Tax Liability Incorrectly
Top Audit Triggers of a CFC that Will Catch the Attention of the IRS. Part Three- Improperly Claiming a Foreign Tax Credit
Top Audit Triggers of a CFC that Will Catch the Attention of the IRS. Part Two- Form 8993
Top Audit Triggers of a CFC that Will Catch the Attention of the IRS. Part Four- Claiming a Loss Associated with Subpart F Income Against GILTI Income
A Walk-Through Form 8992-U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (“GILTI”)
Demystifying IRS Form 5472
The IRS Clarifies the Regulations for the High-Tax Exception to GILTI
The Most Costly Mistakes of CFC Shareholders that Catch the Attention of the IRS. Part Five- Failure to Charge Arm’s-Length Rate of Interest on Intercompany Loans or Advances
Income Tax Consideration of Property Inherited from a Foreign Individual
The Most Costly Mistakes of CFC Shareholders that Catch the Attention of the IRS. Part Six- Failing to Disclose GILTI Income on Schedule H of Form 5471
How is the GILTI High-Tax Exemption Treated for Purposes of Section 959?
The IRS Makes Significant Changes to Schedule H of Form 5471
The Most Costly Mistakes of CFC Shareholders that Catch the Attention of the IRS. Part Seven- Making a 962 Election and Failing to File Forms 1116 and 1118
Tax Relief for Farmers Impacted by Drought
U.S. Real Property Interest Non-Recognition Transfers- Can the IRS Assess Interest When No Tax is Due?
A Closer Look at the “Related Transaction” Rules for the Federal Crime Know as Structuring
Top Five Considerations for Anyone Considering Expatriating from the United States
The Unintended Collateral Consequences of Entering into the OVDP for Immigrants
What is a CFC for Purposes of Filing a Form 5471?
4 Different Branches of Business Law
Introduction to International Income Tax Treaties
The Foreign Compliance Intricacies Associated with Using the United States Indonesia Tax Treaty
Transfer Pricing for Intangible Property
Transfer Pricing for Tangible Property
Demystifying the 962 Election
Cross-Border Lending of Related Parties Requires Attention be Given to Transfer Pricing and Earnings Stripping Rules
Demystifying the All New 2020 Tax Year IRS Form 5471 Schedule J
Will Taxes Increase in 2021?
Demystifying the All New 2020 Tax Year IRS Form 5471 Schedule E Reporting and Tracking Foreign Tax Credits
Can a 962 Election be Used to Defer and Reduce a Delinquent Transition Tax?
Demystifying the All New 2020 Tax Year IRS Form 5471 Schedule P Tracking “Previously Taxed Earnings and Profits of U.S. Shareholder of Certain Foreign Corporations”
So Your Candidate Did Not Win the Election and You Want to Expatriate- Here is What You Need to Know About Expatriation, the Exit Tax, and the New Federal Inheritance Tax
Can You Utilize an LLC to Hold Stock Options in a Self-Directed IRA?
How a Non-Resident Can Use a Tax Treaty to Eliminate the U.S. Tax Consequence of Withdrawing Money from an IRA or 401(k) Plan
Claiming a Tax Treaty Benefit in a Foreign Country or Want to avoid Paying VAT? Make Sure You Obtain a Form 6166
Adding Shares of a DISC to a Roth IRA in Excess of the Statutory Limits- Clever or Unseemly?
A Quick Look at the PTEP Basis Adjustment Rules For CFC Stocks
What Happens When You Marry a Nonresident Alien for U.S. Tax Purposes?
Can “Knowhow” Constitute Property in Exchange for Stock of a Foreign Corporation Under a Section 351 Tax-Free Exchange?
Cross-Border Taxation of the Digital Economy
Things to Know About the 2021 Tax Season
The U.S. Tax Effects of Entities Used by Foreign Investors
A Deep Dive Into U.S. Estate and Gift Tax Treaties
The GILTI High-Tax Election for Multinational Corporations- Be Careful What You Wish For
Common Mistakes CFC Shareholders or Their Advisors Make When Computing Tested Income and Tested Loss for the GILTI Taxing Regime
A Brief Introduction to the Brand New Schedule Q and Schedule R for IRS Form 5471
What International, Corporate, Estate, and Individual Taxes May Look Like Over the Next Four Years
Demystifying IRS Form 1116- Calculating Foreign Tax Credits
With Mega Million, Power Jackpots Swelling to $1.6B Combined, the Valuation of Large Lottery Payouts Remains an Open Question for Purposes of the Estate Tax
An Overview of the Rules Governing the Calculation of Foreign Tax Credits
A Deep Dive Into the GILTI Taxing Regime and CFC GILTI Tax Planning
Mistakes on Your Taxes Can be Costly
A First Impression of the Expatriation “Inheritance Tax”
How a Treaty-Tie Breaker Provision May Save Departing Long-Term Green Card Holders from the Expatriation Tax
The New Tax Laws Governing Foreign Persons or Entities Sale of U.S. Partnership Interests
Does Section 4975 Permit an IRA Account Holder to Establish an IRA Grantor Trust Investment Vehicle and Act as the Trustee of the IRA Grantor Trust?
Attention All Home Buyers
Self Directed IRAs The Long Reach of IRC 4975 Prohibited Transactions
Tax Deadline Approaching for 2021
FORM 3520 / 3520A NOT REQUIRED FOR CERTAIN TAX FAVORED FOREIGN TRUSTS
How to Determine a U.S. Shareholder’s Pro Rata Share of GILTI if a Foreign Corporation is a CFC for Part of Its Tax Year
An Overview of the New Anti-Hybrid Rules and Anti-Conduit Rules Governing Transactions Subject to International Taxation and Some Planning Ideas
A Closer Look at International Tax Arbitrage and the Dual Consolidated Loss Rules
Can a “Leveraged Lease” Avoid the New Anti-Conduit Provisions of the Code?
Reducing U.S. Taxes While Living Abroad
The Roller-Coaster Ride is Over: IRS Loses Battle to Render PPP Business Deductions Non-Deductible
The Conduit Regulations and Multinational Financing Transactions Between Cross-Border Subsidiaries
Major Estate and Gift Tax Increase Proposed in the Senate
Can a “Leveraged Lease or License” Avoid the New Anti-Conduit Regulations Revisited with a Touch of Hungarian Spice
What is a Fungible Token (NFT) and How is a NFT Taxed?
A Line-by-Line Review of the IRS Form 5471 Schedule M
Attention All Home Buyers Part II: FIRPTA and the Statute of Limitations
A Closer Look as to How FDII Can Reduce the Effective Corporate Tax Rate to 13.125%
Fighting IRS Form 3520 Penalties- Your Best Defense is Your Offense
Facing a 965 Transition Tax Audit? Maybe a 962 Election Can Save the Day
Many Fortune 500 Companies Use Foreign Subsidiaries to Avoid Paying U.S. Tax- Here is One Way Your Foreign Corporation Can Avoid Paying U.S. Income Tax
Cross-Border Debt Planning with the Portfolio Interest Exemption Rules
Navigating the Rules for Gain Recognized on a Shareholder’s Disposition of CFC Stock with Untaxed Accumulated E&P
A Deep Dive Into Form 5471 Schedule H “Calculating the E&P of a Controlled Foreign Corporation”
A Deep Dive into the IRS Form 5471 Schedule J
A Deep Dive Into IRS Form 5471 Schedule P
A Deep Dive Into the IRS Form 5471 Schedule E Reporting and Tracking Foreign Tax Credits
When Can the Administrative Record in an IRS WhistleBlower Case Be Supplemented?
There May Be 50 Ways To Leave Your Lover But You May Only Utilize A CDP Challenge to Contest a Form 3520 Penalty Without Prepayment
A Deep Dive Into the IRS Form 3520-A
A Deep Dive Into the IRS Form 3520
Can a Intentionally Defective Grantor Trust Coupled with a Self-Canceling Installment Note ‘Magically’ Remove High Value Assets From an Estate?
An Unusual LOB Provision Contained in the U.S.-Cyprus Tax Treaty May Allow a Resident of a Non-Treaty Country to Obtain the Benefits of the U.S.- Cyprus Tax Treaty
Tax Free Mergers and Acquisitions under IRC 368 What Worked and What Didn’t
TAXPAYER PREVAILS IN FBAR CASE NON-WILLFUL FBAR PENALTY COMPUTED PER YEAR – NOT PER ACCOUNT
Can a Foreign Investor Utilize a “Triangular” Tax Treaty Position to Reduce or Eliminate FDAP and FIRPTA Withholdings?
Two Potential Strategies to Avoid the Section 367 “Toll Charge” on the Outbound Transfer of Intellectual Property
International Tax-Free Exchanges and the Deemed Royalty Regime for Intellectual Property
Taking the 3520 Penalty Fight to the IRS by Attacking the Penalty on Technical Grounds
Demystifying International Tax-Free Reorganization, Divisions, and Mergers and Acquisitions
Thinking About a Cross Border Tax-Free Reorganization or Merger? Better Consider Section 367
Demystifying International Forward and Reverse Tax-Free Mergers
The Corporate Anti-Inversion Rules- Don’t Leave Home Without Understanding Them
A Dive into the IRS Form 5471 Schedule F
Foreigners Holding U.S. Real Estate Multi-Tiered Corporations- An Accidental Inversion Just Waiting to Happen
The New CFC Attribution Rules and How These Rules Can Cause Domestic Investors to be Classified as “SFC” Shareholders
What Foreign Investors Should Know About the Branch Profits Tax and Withholdings Before Investing in the United States
A Dive into the New Form 5471 Categories of Filers and the Schedule R
A Closer Look at the Process of Reducing a FIRPTA Withholding
The Taxation of Dispositions of Partnership Interests by Foreign Persons
When Foreigners Own U.S. Real Property: Planning for the Estate and Gift Tax Associated with U.S. Property Ownership
Criminal and Civil Forfeitures Involving Cryptocurrency: An Introduction to Federal Forfeiture Processes
Calculating the Foreign Tax Credit- Don’t Put All Your Eggs in One Basket
Bringing the 3520 Penalty Fight to the IRS- Contesting a 3520 Penalty in Tax Court
Four Lines of Defense to a Form 5471 Penalty
Tax-Free Demergers in the International Context
Four Lines of Defense to a Form 5472 Penalty
Unraveling the United States- People’s Republic of China Income Tax Treaty
Unraveling the United States- Republic of Korea Income Tax Treaty
Unraveling the United States-Canada Income Tax Treaty
The Cross-Border Tax Implications of Canadians Holding U.S. Real Property
A Deep Dive Into the United States-United Kingdom Income, Gift, and Estate Tax Treaties
Unraveling the Controversial United States- Hungary Income Tax Treaty
Unraveling the United States- India Income Tax Treaty
Business Impact of the United States- France Income Tax Treaty
Unraveling the United States- Mexico Income Tax Treaty
Unraveling the United States- Ireland Income Tax Treaty
Did You Get an Audit Notice?
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
Unraveling the United States- Israel Income Tax Treaty
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
The Immigration Consequences Counsel Should Understand When Representing a Noncitizen Who is Criminally Prosecuted for Failing to Disclose Foreign Income or Foreign Bank Accounts
Defense Considerations in an IRS Criminal Tax Investigation- Cooperation Versus Non Cooperation
A Deep Dive into the 2021 IRS Form 5471 Schedule J
The Fourth Amendment Protection Against Unreasonable Search and Seizure in an IRS Criminal Tax Evasion or CriminalTax Fraud Case
The Fifth Amendment Right to Remain Silent in an IRS Criminal Tax Evasion or Criminal Tax Fraud Case
Tracking Form 5471 Section 959 PTEPs on Schedule J for the Modern Day CFC
Are Holiday Gifts from Employers Taxable?
International Treaty Law that Permits Non-Residents to Withdraw Funds from their IRAs or 401(k) Funds and Avoid Any and All U.S. Tax Consequences
Cross-Border Reorganizations, Mergers and Acquisitions and the Application of Internal Revenue Code Section 367
Will a Voluntary Disclosure of Unreported Income to the IRS Really Protect You From Criminal Prosecution?
The Tax-Free Withdrawal of U.S. Based Retirement Funds by Non-U.S. Citizens through Income Tax Treaties
An Introduction to Type A Corporate Tax- Free Reorganizations
An Introduction to Type A Forward and Reverse Triangular Tax-Free Mergers
International CorporateTax-Free Mergers and Acquisitions- is there Anywhere to Hide from Section 367?
An Overview of Type B Tax-Free Reorganizations and Type B Tax-Free Triangular Reorganizations
An Overview of Type C Tax-Free Reorganizations and Type C Tax-Free Triangular Reorganizations
An Overview of Type F Tax-Free Reorganizations
An Overview of Type E Tax-Free Reorganizations
One Potential Strategy Foreigner Investors Can Utilize to Transfer U.S. Real out of their Estate to Avoid the Estate and Gift Tax
When Foreigners Own U.S. Real Property: Planning for the Estate and Gift Tax Associated with U.S. Property Ownership with an Emphasis on Partnerships
One Potential Strategy Foreigner Investors Can Utilize to Transfer U.S. Real Property out of their Estate to Avoid the Estate and Gift Tax
What are the Tax Deadlines for 2022?
The Importance of Digital Evidence and Digital Forensics in a Criminal Tax Case
Indirect Methods that the IRS Uses to Establish Criminal Tax Evasion and Potential Defenses
Specific Methods that the IRS may use to Establish Criminal Tax Liability and Potential Defenses to these Methods
Some Common Defenses in Criminal Tax Cases
Why Disclose Your Foreign Assets to the IRS in 2022?
Cross-Border Debt Planning with the Portfolio Debt Rules With an Emphasis on Complying with the Bond Registration Rules
Civil Asset Forfeiture What To Do If Your Assets Have Been Seized by the U.S. Government
Can Chinese Investors in U.S. Real Estate Skirt the $50,000 Transfer Limit by Using Cryptocurrency Trading Agreements?
Stock Acquisitions Treated as Asset Acquisitions under Section 338
A Closer Look at Taxable Corporate Mergers and Acquisitions
A Closer Look at Tax-Free Corporate Divisions or Type D Reorganizations
The Corporate Transparency Act- A New FinCEN Filing Requirement With Significant Delinquency Penalties
Don’t Expatriate from the U.S. to Avoid the PFIC or GILTI and Subpart F Regimes- Keep Your U.S. Citizenship and Become a Resident of Puerto Rico Instead
Planning Options to Defer the Recognition of Subpart F or GILTI Income- Section 962 Election vs. High-Tax Exception: The Epic Showdown
The 2022 Guide to Income and Estate Taxation of Cryptocurrency and NFTs or Non-Fungible Tokens
The Current State of the IRS OVDP and an Overview of the Pre-Clearance IRS CI Form 14457
Has the IRS Assessed You a Penalty for a Late Filed Form 3520-A? You May Be Eligible For an Abatement of Penalties Assessed or a Refund of Penalties Paid
Can Holding or Blocker Company be Used to Reduce GILTI Tax Liability?
State of California Residency Considerations for Non-resident Corporate Executives that are Physically Present in California Part-Time
Why Should You Have a Lawyer Do Your Tax Prep?
The Participation Exemption Rules Available for Domestic Corporations to Avoid GILTI Inclusions and a Discussion Regarding the Anti-Hybrid Limitations to the Participation Exemption Rules
Been Assessed Penalties by the IRS for Failing to Report a Foreign Pension Plan or Retirement Plan on Forms 3520 or 3520-A? Consider Requesting Relief Under Rev. Proc 2020-17
Planning Opportunities Available for Foreign Persons to Eliminate or Significantly Reduce Taxable Real Estate Gains through Shared Appreciation Loans and Income Tax Treaties
An Overview of the California Water’s Edge Election for State International Tax Purposes
Demystifying the New 2021 IRS Form 5471 Schedule E and Schedule E-1 Used for Reporting and Tracking Foreign Tax Credits
Demystifying the 2021 IRS Form 5471 Schedule J
How An IC-DISC Can be Used to Defer Tax On Commissions Related to $10 Million of Export Sales Per Year
The Taxation of Cross-Border Currency and Hedging Transactions
Unraveling the United States- Philippines Income Tax Treaty and a Closer Look at the Treaty’s Provision Regarding the Taxation of U.S. Based Retirement Accounts Such as 401K Plans and IRAs
Demystifying the 2021 IRS Form 5471 Schedule Q
A Discussion as to How Foreign Investors Can Use Shared Appreciation Mortgages to Avoid FIRPTA Withholding Associated with the Sale of U.S. Real Estate
Limited Escape Hatch: Do You Need to File Form 8938 ‘Statement of Specified Foreign Financial Assets’?
Unraveling the United States- Switzerland Income Tax Treaty and the Treaty’s Impact on the Global Taxation on Cross-Border Pension Plans
Unraveling the United States- Spain Income Tax Treaty and the Treaty’s Impact on the Global Taxation on Cross-Border Pension Plans
Unraveling the United States- Philippines Income Tax Treaty and a Closer Look at the Treaty’s Provision Regarding the Taxation of U.S. Based Retirement Accounts Such as 401K Plans and IRAs
Unraveling the United States- Germany Income Tax Treaty and the Treaty’s Impact on the Global Taxation of Cross-Border Pension Plans
Unraveling the United States- Netherlands Income Tax Treaty and the Treaty’s Impact on the Global Taxation of Cross-Border Pension Plans
The U.S. Tax Consequences of Terminating U.S. Residency With PFIC Shares and Potential Planning Options
A Guide to the Taxation of Crypto Staking and How Investors Can Calculate Their Basis In Staking Rewards
What Constitutes a Foreign Branch?
A Win for Taxpayer in Non-Willful FBAR Penalty Case In The Ninth Circuit Court of Appeals
Crossborder Taxation of Retirement and Pension Plans Under the U.S.- U.K Tax Treaty
Crossborder Taxation of Cloud Transactions and Digital Downloads
Crossborder Taxation of Retirement and Pension Plans Under the U.S.- India Tax Treaty
How Cryptocurrency “Hard Forks” and “Airdrops” Are Taxed
Taxation of the Digital Economy- A Brief Overview of the OECD Two-Pillar Proposal
Can U.S. Remote Workers Trigger Foreign Income Tax or Foreign Employment Tax Liability for U.S. Companies? An OECD Perspective
Crossborder Taxation of Retirement and Pension Plans Under the U.S.- Canada Income Tax Treaty
The Risks U.S. Companies Should Consider before Hiring a Foreign Independent Contractor
Given the Way the U.S.- Cyprus Income Tax Treaty’s LOB is Drafted, Does it Really Matter if the U.S.- Russia Income Tax Treaty is Canceled?
Demystifying the QDOT in the Context of Cross-Border Estate Planning
A Closer Look at Cross-Border Estate Planning for Foreign Investors Utilizing Estate Tax Treaties and Corporate Structures
The Pros and Cons of Using a “Multi-Tiered Blocker Structure” to Avoid FIRPTA
A Closer Look as to How a Foreign Investor May Utilize a Section 897(i) Election to Avoid FIRPTA Withholding
Demystifying the 2021 Tax Year IRS Form 5471 Schedule P Tracking “Previously Taxed Earnings and Profits of U.S. Shareholder of Certain Foreign Corporations”
Demystifying the 2021 Schedule M “Transactions Between Foreign Corporations” of IRS Form 5471
Demystifying Schedule O Used to Report Foreign Corporate Reorganizations and Acquisitions on IRS Form 5471
A Closer Look at the Schedule R Used to Disclose Distributions from Foreign Corporations to CFC Shareholders on IRS Form 5471
A Review of the 2021 Form 8992-U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (“GILTI”)
A Closer Look at the 2021 Schedule I-1for IRS Form 5471
Filing a Tax Extension
Fighting IRS Form 3520 Penalties- Your Best Defense Maybe Your Offense
An Overview of Reporting Deemed Paid Foreign Tax Credits Related to GILTI Inclusions of an S Corporation on Part III, Section 3 for the New IRS Schedule K-3
Final Regulations Issued Regarding Partnerships and S Corporations that Hold Controlled Foreign Corporations
There May Be 50 Ways To Leave Your Lover- But You May Only Utilize A CDP Challenge to Contest a Form 3520 Penalty Without Prepayment
Utilizing the U.S.- China Tax Treaty to Avoid U.S. Withholding Tax and Early Withdrawal Penalties From a 403(b) Plan
A Closer Look as to How Nonresidents Can Utilize the U.S.- Korean Income Tax Treaty to Avoid U.S. Taxation Associated With a Domestic Retirement Plan Distributions
The IRS Form 5472 Reporting Requirements for Foreign Owners of a U.S. Disregarded Entity
The United States-Canada Income Tax and Estate Tax Treaty Revisited
The U.S. and Canadian Tax Consequences of a Canadian Investor’s Acquisition of U.S. Real Estate
The IRS Multinational Audit: How Multinational Corporations Can Survive Five Common Targets of an IRS International Tax Audit
Be Careful with Loans to Controlled Foreign Corporations – a Loan to a Foreign Corporation Can Trigger a Form 5471 Filing Requirement
How to Utilize Section 6751 to Successfully Challenge IRS 3520 Penalties
How to Utilize Section 6751 to Successfully Challenge IRS 5472 Penalties
Unraveling the Mystery of Reporting Foreign Retirement Plans to the IRS
Navigating the Maze of the Complex Money Transmitter Laws of Cryptocurrency
A Brief Overview of the Estate and Gift Tax Considerations Associated with the Transfer of Cryptocurrency
How to Survive a Cryptocurrency IRS Tax Audit
Got Cryptocurrency? Here is What You Need to Know About Estate Planning, Crypto Memorandums, and RUFADDA
Cryptocurrency Tax Accounting Decoded- Using HIFO Tax Accounting to Shield Crypto Gains from the IRS
Planning Options to Increase the Section 1202 Gain Exclusion Far Beyond the $10 Million Cap
The Guide to Claiming Cryptocurrency Tax Losses
How the Sale of an NFT May Trigger a Painful Tax Surprise for Some Investors
The Tax Treatment of Charitable Contributions of Cryptocurrency to Public Charities and Private Foundations
A Closer Look at the Road to Indictment in an IRS Criminal Tax Fraud Case
The Crimes an Individual Targeted by an IRS Criminal Tax Fraud Investigation May Ultimately Find Himself Charged With
Did You Receive Notice of an IRS Audit?
An Introduction to the Form 5471 Filing Categories of the Modern Day Foreign Corporation and a Brief Look at the Taxation of CFC Income
A Tax Professional’s Guide to Form 5471 Schedule J and Schedule H
A Tax Professional’s Guide to Form 5471 Schedule E and Schedule H
The Rising Significance of Self-Cancelling Installment Notes as a Estate-Planning Tool for U.S. Citizens and Nonresidents
A Closer Look at the Title 31 Anti-Money Laundering Rules Governing Cryptocurrency Exchangers
Todd and Julie Chrisley Were Found Guilty of Tax Evasion- So What is Tax Evasion?
Will ‘Chrisley Knows Best’ Reality TV Stars Face Prison Sentences? A Brief Discussion Regarding the Sentencing of Defendants Convicted of Tax Fraud
An In Depth Look at the IRS Form 8858 Used With Respect to Foreign Disregarded Entities and Foreign Branches
An In Depth Look at the IRS Form 8865 and the Foreign Partnership Reporting Provisions of the Internal Revenue Code
Reporting Cross-Border Transfers and Reorganizations on IRS Form 926
A Closer Look at Gain Recognition Agreements in the Context of Cross-Border Transfers and Reorganizations
IRS Form 3520 in a Nutshell
An Overview of FIRPTA Withholding and a Discussion How to Avoid FIRPTA Withholding on a 1031 Exchange
An Overview of the Expatriation Tax and the New Federal Inheritance Tax
Cross-Border Intercompany Transfers of Intangible Property and Cost Sharing Arrangement Considerations for Multinationals
The Rules Governing Cross-Border Intercompany Transfer Pricing of Intangible Property for Multinational Corporations
Exploitation of Intangible Property Rights Abroad: The Tax Incentives to Licensing under FDII
The United States- Hungary Income Tax Treaty- Last Call!
How to Treat IRA and 401(k) Plans in an Expatriation
A Foreign Investor’s Guide to U.S. Real Estate Investment Trusts
Exploitation of Intangible Property Abroad: The Use of Cost Sharing Arrangements to Avoid the Transfer Pricing Rules
The Tax Consequences Associated With Making Loans or Advances to a Foreign Corporation
The Taxation of RSUs in an International Context
IRS Aims to Clear Backlog by 2023
Planning for Foreign Investors Investing in U.S. Real Estate to Eliminate the U.S. Estate and Gift Tax
RSUs and the Expatriation Tax
RSUs and the Expatriation Tax
How Digital Evidence Can be Obtained from Computers, Smartphones, and Social Media Platforms
An In Depth Look into U.S. Estate, Gift, and Generation-Skipping Tax Treaties
Are You Ready for the Tax Extension Deadline?
A Deep Dive Into the IRS Form 5471 Attribution Rules, Form 5471 Category of Filers, and the Safe Harbor Rules
Common Issues that Lead to Tax Audits
Why the Anti-Inversion Rules Make the Holding of U.S. Real Property through Multi-Tiered Blocker Structures Worthless to Foreign Investors
An Introduction to the Secure Act for Qualified Retirement Plans and IRA Minimum Distribution Rules
Cross-Border Corporate Reorganizations and the Use of Gain-Recognition Agreements to Avoid Significant Adverse Tax Consequences
Thinking About Starting a Private Foundation? Proceed With Extreme Caution
A Brief Look at the Hurdles Involved in a Type F Cross-Border Reorganization
Dual American British Residents- Will Uncle Sam or King Charles Tax Your Estate?
The IRS’s Ability to Access Electronic Communications Under the Stored Communication Act
Think You Can Delete Incriminating Evidence From Your Computer and an IRS Criminal Tax Investigator Won’t Notice? Think Again
The High-Tax or Section 954 Election for Multinational Corporations
A Walk through the Cost Sharing Arrangement and Platform Contribution Rules
When Should I Call a Tax Attorney?
The Impact of Revenue Procedure 2019-40 on GILTI and Subpart F Inclusions
A Closer Look at the Form 5471 Filer Rules and the Upward and Downward Attribution Rules
The Separate Basket Limitations for Foreign Tax Credits
Is a 962 Election the Cure for the Hardships Caused by GILTI or Subpart F Inclusions?
What Foreign Nationals Relocating to the U.S. Needs to Know About the Check-the-Box Rules
Has the IRS Been Illegally Assessing 3520 Penalties all this Time? What to do If the IRS Unlawfully Assessed a 3520 Penalty Against You
Planning Ideals for the Modern Day International Corporate Merger or Reorganization
Has the IRS Been Illegally Assessing 5472 and 5471 Penalties all this Time? What to do If the IRS Unlawfully Assessed Such a Penalty Against You
Cross-Border Corporation Divisions or Demergers under Section 355
The Cross-Border Taxation of Cloud Transactions and Digital Downloads
Foreign Contractors- To Withhold or Not to Withhold in a Digital Age
The Corporate Anti-Inversion or Expatriation Rules Explained in a Nut-Shell
Cross-Border Financing and the Importance of the Registration Rules
An Overview of the FIRPTA Withholding Rules and Planning Ideas to Avoid FIRPTA Withholding
Tax Goals for 2023
A Brief Overview of the Form W-9 and W-8 for Purposes of Withholding
Can a Gift of Cash from Abroad Trigger a Gift Tax Obligation to the U.S. Recipient?
An Overview of the Rules Governing Hybrid Arrangements
Cross Border Conduit Financing and the Intricate Rules Governing These Transactions
What Every Nonresident that Jointly Owns U.S. Property Should Know About the Federal Estate Tax
Litigating a Case in Tax Court: A Litigation Tutorial
Facing an IRS Section 965 Transition Tax Audit? Maybe a 962 Election Can Save the Day
How to Sue the IRS for Damages Associated with the Failure to Release a Lien
Can Sections 7432 and 7433 be Used to Recover Damages from the IRS for the Collection of Section 3520, 5471, and 5472 Penalties?
How Quarterly Tax Payments Work
Received a Gift from an Individual that Expatriated the U.S.? You May Owe the IRS Gift Tax
Can Article 4 of the US-UK Estate, Gift, and Generation Skipping-Tax Treaty be Utilized to Avoid the U.K. Inheritance Tax?
An Introduction to the Taxation of the Modern Day Cross-Border Merger and Acquisition
Beware of Section 956 Constructive Dividends Resulting from Short-Term Cross-Border Intercompany Loans
Do IRS International Penalties Qualify for First Time Relief?
It is About to Get Much More Difficult to Claim a Foreign Tax Credit A Look at the 2022 Final Foreign Tax Credit Regulations
Tax Planning Tips for Couples Involved in a Cross-Border Divorce
Totalization Agreements vs. Tax Treaties
Is the Statute of Limitation for IRS Assessed Foreign Information Reporting Penalties for Collections Five or Ten Years?
Are IRS Assessed Foreign Information Reporting Penalties Associated with Forms 3520, 5471, and 5472 Ripe for a Prepayment APA Suit?
Filing Tax Forms for Employees and Contractors
The Foreign Trust “Throwback Tax” and a Guide to Reporting the “Throwback Tax” on a Form 3520
How to Make a Competent Authority Request to Resolve a Tax Treaty Dispute
Form 5472- The Hidden Reporting Requirement for Foreign-Held Disregarded Entities
How to Calculate the Tax on Sale of a Partnership Interest of a Foreign Investor
Criminal Tax Law in San Francisco, California: What You Need to Know
From Investment Vehicles to Treaties- What Foreign Investors Need to Know About Cross-Border Estate Planning
Can Your Self-Directed IRA Hold Stock Options?
Tax Planning for Inbound Licenses of Intellectual Property in a Post 2017 Tax Cuts and Jobs Act World
U.S. Taxation of International Cloud Computing and Digital Transactions
Once the U.S.-Hungary Income Tax Treaty Terminates- Can Hungarian Owned Entities be Treated as “Equivalent Beneficiaries” For Tax Treaty Purposes?
TAXATION OF THE MODERN DAY CROSS-BORDER MERGER AND ACQUISITION
The 2023 Tax Guide for Cryptocurrency and NFTs
How is Crypto Staking Taxed Post Jarrett?
California Tax Attorneys: Navigate the Complex Tax Landscape with Diosdi Ching & Liu
Demystifying the 2023 IRS Form 5471 Schedule J
Can a Tax Treaty Tie-Breaker Provision Save Departing Residents from the Expatriation Tax?
How to Determine the Tax on a U.S. Partnership Interest of a Foreign Person
An Overview of the Rules Governing Tax-Free Corporate Reorganizations of Section 355
Introduction to the Taxation of Corporate Divisions
Navigating Tax Challenges with a San Francisco Tax Litigation Attorney
Tax Planning for U.S. Inbound Licenses of Intellectual Property in a Post U.S.-Hungary Tax Treaty World
Challenges Associated with the Sourcing of Computer Programs for Purposes of the U.S. Cross-Border Tax Sourcing Rules
Foreign Persons Doing Business in the United States- Tax and Treaty Considerations
Do the Anti-Conduit Regulations Delegate Authority to the IRS to Override Tax Treaties?
A Deep Dive into the FIRPTA Rules
A Closer Look at the Benefits of Cross-Border Finance Transactions that are Characterized as Portfolio Debt
Can a Foreign Tech Company be Subject to U.S. Tax on Internet-Related Income by Utilizing U.S. Servers?
Diosdi Ching & Liu, LLP: Experienced San Francisco Tax Law Attorneys
To Withhold, or Not to Withhold, That is the Question For Foreign Workers
The U.S. Taxation of Foreign Computer Programs and Cloud Computing Transactions
Secure Your Financial Future with Diosdi Ching & Liu, LLP: Your Reliable San Francisco Tax Law Attorneys
Does the Farhy Decision Apply to 3520 Penalty Assessments?
What is Superannuation and How it Could be Taxed Under the United States- Australia Income Tax Treaty
Here Comes the Employee Retention Credit Enforcement, There Goes the Criminal Indictments
A Look at Schedule G of Form 5471 Used to Report Cost Sharing Arrangements of Controlled Foreign Corporations
Demystifying the 2023 Form 5471 Schedule E Used to Report and Track Foreign Tax Credits of Controlled Foreign Corporations
Hiring the Right San Francisco Tax Law Attorneys: Why Choose Diosdi Ching & Liu, LLP?
Income, Gift, Estate, Generation-Skipping, and State Tax Considerations Associated with Establishing and Administering Trusts
An Introduction to the Corporate Transparency Act
What is an RRSP and How is it Taxed Under the United States- Canada Income Tax Treaty
What Hungarian High Tech Companies Need to Know Now that the U.S.-Hungarian Tax Treaty Will be Terminated
A Deep Dive Into the New 2022 IRS Form 3520
A Deep Dive Into the New 2022 IRS Form 3520-A
Dynasty Trusts- the Most Powerful Planning Available to Combat the Estate, Gift, and the Generation Skipping Tax
A Closer Look at FTB Notice 2023-02 Offering Settlement for Micro-Captive Insurance and Syndicated Conservation Easement Tax Motivated Transactions
Basic U.S. and Canadian Tax Considerations of Canadian Investment in U.S. Real Estate
Tax Law Attorneys in San Francisco, California: Why Choose Diosdi Ching & Liu, LLP?
Top Eight Considerations for Anyone Considering Expatriating from the United States
Demystifying the New 2022 IRS Form 5472
Is the Exit Tax Constitutional?
Is the Section 965 Transition Tax, Subpart F, and GILTI Constitutional?
The United States- Japan Income Tax Treaty and a Closer Look at Issues Involving “Hybrid Entities” in the Taxation of International Transactions
A Closer Look at the U.S.-Japan Estate and Gift Tax Treaty
Factors to Consider When Developing a Strategy to Contest a 3520 Penalty
When Are You Required to File a Form 3520 with the IRS?
Why You Need an Experienced Tax Law Attorney in San Francisco, California
Foreign Cloud Computing Transactions: U.S. Taxation of Service, Intangible, Copyright, and Royalty Income
Questions Regards U.S. Federal Tax Consequences of India’s Provident Fund Schemes Under the U.S.-India Income Tax Treaty
An Introduction to the Tax-Free Corporate Reorganization Rules
The Taxation of Affiliated Corporations and Computing Consolidated Taxable Income
A Brief Overview of Taxable Corporate Mergers and Acquisitions
A Closer Look at the U.S.-France Estate and Gift Tax Treaty
Navigating San Francisco’s Tax Landscape: Choosing the Right Tax Attorney
A Closer Look at the U.S.- Germany Estate and Gift Tax Treaty
A Closer Look at the U.S.- U.K. Estate and Gift Tax Treaty
An Overview of the Federal Taxation of S Corporations
The Tax Consequences of Liquidating C Corporations
How to Determine the Withholding Tax on a Foreign Partner’s Partnership Interest
A Closer Look at the U.S.- Canada Tax Treaty Article Governing the U.S. Estate Tax
Determining Taxable Gains from the Sale of CFC Stocks
FIRPTA and the Benefits of a Section 897(i) Election
The Application of the Anti-Conduit and Anti-Hybrid Regulations to Hybrid Entities and Hybrid Instruments
San Francisco Tax Lawyers: Your Allies in Complex Tax Matters
What is an Initial Appearance/Arraignment in a Federal Criminal Tax Case?
Can a CFC Shareholder Pledge CFC Shares as Security for a Loan?
How is a Sentence Determined in a Criminal Tax Case?
San Francisco Tax Lawyers: Expertise That Counts
A Basic Guide to GILTI
Tracking Form 5471 Section 959 PTEPs of the Modern Day CFC
The IRS Form 5471 Category Filer Rules
A Basic Guide to Subpart F Income
A Basic Guide to GILTI and Schedule I-1 for Form 5471
A Dive Into Subpart F Income and Schedule I of the Form 5471
The Reshoring or Domesticate of a Controlled Foreign Corporation
No, No, No, No….Prohibited Transactions and Disqualified Persons in Self-Directed IRAs
The 962 Election vs. The High-Tax Exception: The Epic Showdown
The Reshoring or Domesticate of a Controlled Foreign Corporation
The Reshoring or Domestication of a Controlled Foreign Corporation
The U.S. Taxation of Foreign Trusts
Understanding the Vital Role of San Francisco Tax Lawyers at Diosdi & Liu, LLP
FIRPTA and the IRS’ Ability to Assess Interest When No Tax is Due
An Introduction to the Taxation of U.S. Real Estate Held by Foreign Investors
Why the IRS Does Not Have the Authority to Assess and Collect a Section 6039F Penalty in Connection With a Late Filed Form 3520
IRS Form 5472: Do You Need to File it?
How to Report Cross-Border Payments to the IRS on Form 1042
How to Report Cross-Border Payments to the IRS on Form 1042-S
Mastering Tax Issues in San Francisco: Why Diosdi & Liu, LLP Stands Out
Dynamo Holdings L.P. v. Commissioner- A Blueprint of How Related-Party Inbound Foreign Investment in U.S. Real Estate Should and Should Not be Handled for FIRPTA and FDAP Purposes
A Closer Look at the W-8BEN Used by Foreign Individuals to Document their Status for U.S. Tax Withholding Purposes
A Closer Look at the W-8BEN-E Used by Foreign Entities to Document their Status for U.S. Tax Withholding Purposes
A Case Study of an Outbound Forward Triangular Reorganization Part II- The Limited Interest Exception
A Case Study of an Outbound Forward Triangular Reorganization
A Closer Look at the W-8BEN-E Used by Foreign Entities to Document their Status for U.S. Tax Withholding Purposes
Demystifying the Use of a Intentionally Defective Grantor Trust
Pushing Back on IRS’s Attempts to Immunize Its Employees from Subpoenas
A Closer Look at the United States- France Income Tax Treaty
A Closer Look at the United States- Italy Income Tax Treaty
Making Sense of Tax Treaty LOB Provisions
An Overview of IRS Form 5471 Schedule R Used to Report Distributions from Foreign Corporations
Examining the Form 5471 Category of Filers
The Application of the Indirect and Constructive Ownership Rules Under Section 958 From Foreign Corporations to U.S. Persons
How the IRS Establishes a Tax Evasion Case
A Beginner’s Guide to Tax Evasion, Money Laundering and Other Criminal Tax Related Crimes
The Most Common Federal Tax Crimes that Aggressive Tax Professionals Should Know
The Court of Claims Expands Foreign Tax Credits to NIIT Under the U.S.-France Income Tax Treaty
An Overview of the Section 911 Income and Housing Exclusion Rules
U.S. Acquisitions by Foreign Corporations and Section 367 Considerations
Planning Considerations of Tax-Free Forward Triangular Mergers for Cross-Border Acquisitions of S Corporations Tax-Free
U.S. Taxpayers Now Can Claim Foreign Tax Credits for Foreign Taxes Assessed on French Contribution Sociale Generalisee and Remboursement de la Dette Sociate
If You Were a Client of Castro & Company You Should Consult With A Qualified Tax Attorney
Does the U.S.-Australian Income Tax Treaty Exclude Superannuation Funds from U.S. Taxation?
Corporate Spinoffs, Split-Offs, and Split-Ups in the International Context
How to Calculate Foreign Tax Credit on Qualified Dividends
The Difficulties of Portfolio Interest Exemption Planning After the Repeal of Section 958(b)(4)
Why Domesticate or Decant a Foreign Non-Grantor Trust
The Impact of a Section 338 Election to CFC Shareholders
Type F Reorganization Considerations for S Corporate Targets
An Overview of the Presentence Investigation Report Process for a Criminal Tax Case Prosecuted in the U.S. District Court of the Central District of California
An Overview of the Presentence Investigation Report Process for a Criminal Tax Case Prosecuted in the U.S. District Court of Northern California
Potential Sentence Reduction for Federal Criminal Tax Defendants
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
A Deep Dive Into the U.S. Tax Consequences of Foreign Investors Holding Domestic Real Estate
Can a “Multi-Tiered Blocker Structure” be Used to Avoid FIRPTA
Specific Criminal Sanctions
The Internal Revenue Service Criminal Investigation Process
Check the Box Regulation Planning
Minimizing U.S. Tax Consequences of U.S. Citizens and Residents Working Overseas
U.S. Tax Planning for Foreigners Intending to own U.S Real Estate
FinCen Form 114 / Treasury Form TD F 90-22.1
Voluntary Disclosures of Foreign Financial Accounts
Is the Sentencing Guidelines’ Zero-Point Offender Provision a Get Out of Jail Free Card for First-Time Criminal Tax Offenders?
An Overview of a Franchise Tax Board Audit and How they are Different than IRS Audits
How the Deemed Royalty Regime for Intellectual Property Operates in Cross-Border Transactions
An Overview of the Civil and Criminal Statute of Limitations For Undisclosed Foreign Financial Assets and Unreported Foreign Income
IRS Reopens Voluntary Disclosure Program for Businesses with Problematic Employee Retention Credits
What Clients and Tax Advisors Can Learn From the Prosecution of John Castro of Castro & Company
An Overview of U.S. Taxation Foreign Pensions
How the Throwback Tax is Calculated on a Foreign Trust Distribution on the Form 3520
CFC Shareholder Planning Considerations for GILTI
How the French Reporting Requirements and Tax May Affect U.S. Trusts
Taxation of Annuities
The Tax Benefits of Utilizing Commercial Annuities
Estate Freezing Techniques Available Through Grantor Retained Annuity Trusts
The Retirement and Estate Planning Benefits of Charitable Remainder Trusts
401K and IRA Considerations that May Influence the Estate Planning Process
The Estate, Gift, and Income Tax Consequences of Utilizing Life Insurance in an Estate Plan
How a Dynasty Trusts Can be Used to Avoid the Generation Skipping-Tax
How is Restitution and the Cost of Prosecution Determined in a Criminal Tax Case
How Qualified Domestic Trusts are Used in Cross-Border Estate Planning
How the “Title Passage Rule” Can be Effectively Utilized to Avoid U.S. Income and Withholding Taxes in Cross-Border Transactions
What Importers Need Know About US Trade and Customs Practices
A Brief Overview of Japanese Taxation
A Brief Overview of Columbian Taxation
An Overview of the Corporate Transparency Act
The Impact of French Tax Law on Dual U.S. French Residents that Utilize U.S. Trusts for Estate Planning
A Closer Look at the United States- Republic of Chile Income Tax Treaty 
How Canadian Real Estate Investors Can Avoid the U.S. Gift Tax Through Marital Deduction Provisions
A Deep Dive into How the PFIC Regime Taxes Foreign Investments
Cross-Border Audits: When Foreign Tax Authorities Sic the IRS on You
How Foreign Corporations Can be Used to Avoid FIRPTA
An Overview of the Source-of-Income Rules and the Taxation of Foreign Computer Programs
How Foreign Corporations Conducting Business in the United States are Taxed
IRS Form 8621 and PFIC Reporting Rules
U.S. Taxation of Stock-Based Compensation Received by Nonresident Aliens
Can Canadian Florida Real Estate Investors Utilize a Lady Bird Deed to Avoid the U.S. Gift Tax?
The Evolution of the Taxation and Reporting of Non-Fungible Tokes
Are There Any Silver Linings in the Proposed Cloud Computing Regs?
The IRS Ends Automatic Section 6039F Penalties for Late-Filed Form 3520s. Six Reasons Why the Announcement Was Inadequate
Tax Consideration Involved in the Domesticating of a CFC
The U.S. Taxation of India’s Provident Fund
The U.S. Taxation of Canadian RRSP Retirement Accounts
How the U.S.-Canada Tax Treaty Treats Retirement Plans
How U.S. Retirement Plans are Treated for Exit Tax Purposes
What is an Aircraft Trust and How They Work for Nonresidents
Does the Seventh Amendment Invalidate International Penalties?
The Benefits of Utilizing Gain Recognition Agreements in Cross-Border Corporate Transfers
How to Plan for the U.S. Exit Tax
Are Foreign Cash Gifts Taxable?
The IRS Finalizes Regulations for the Section 2801 Inheritance Tax
Will Loper-Bright Have Any Impact on Tax Litigation with the IRS?
How Use a Section 6751(b)(1) Defense in an International Penalty Case
Is it Possible to Quash an IRS Summons Issued to Build a Civil or Criminal Tax Case in a Foreign Country?
How Fourth Amendment Can be Utilized to Challenge an IRS Summons
How Does the Fifth Amendment Privilege Against Self-Incrimination Apply in a Criminal Tax Case?
Demystifying Form 5471 Schedule E and E-1 Used to Report and Track Foreign Tax Credits of Controlled Foreign Corporations
Demystifying Form 5471 Schedule E and E-1 Used to Report and Track Foreign Tax Credits of Controlled Foreign Corporations
Demystifying Form 5471 Schedule P
Demystifying IRS Form 5471 Schedule O Used to Report the Organization and Reorganization of a CFC
Demystifying the New IRS Form 5471 Schedule M Used to Report CFC Transactions with Related Parties
Demystifying IRS Form 5471 Schedule G
Demystifying IRS Form 5471 Schedule J and the New Proposed PTEP Regulations
A Deep Dive into IRS Form IRS Form 5471 Schedule G-1 Used to Disclose Multinational Corporate Cost Sharing Arrangements
A Deep Dive into IRS Form IRS Form 5471 Schedule I-1 Used to Determine GILTI Income Inclusions
A Deep Dive into IRS Form 5471 Schedule I Used to Report a U.S. Shareholder’s Share of Subpart F Income
An Overview of the IRS Form 5471 Schedule Q
An Overview of IRS Form 5471 Schedule R
An Overview of IRS Form 5471 Schedule H
A Close Look at IRS Form 5471 Schedule F Used to Disclose a CFC’s Balance Sheet
A Deep Dive Into the 2024 IRS Form 3520-A Used to Provide Information About Foreign Trusts to the IRS
A Deep Dive Into the 2024 IRS Form 3520 Used to Report Transactions with Foreign Trusts and Receipt of Foreign Gifts
Did John Castro (or His Related Party AITAX.com) Advise you a Treaty can be used to Exclude Australian Superannuation Funds from U.S. Taxation? Here is How a Superannuation Fund is Taxed in the U.S.
A Deep Dive into the United States-Canada Income Tax Treaty
An Overview of the United States- Mexico Income Tax Treaty
What Foreign Owners of U.S. Disregarded Entities Need to Know About U.S. Tax Filing Requirements
GILTI vs. FDII Who’s the Hero and Who’s the Villain?
Can the Transition Tax and GILTI Regulations be Challenged Under the RFA?
An Overview of the Tax Consideration of Moving IP Outbound
How Dual Citizens Can Escape the U.S. Exit Tax
Cross-Border Tax and Estate Planning Considerations for U.S. Citizens that Plan Reside in France
U.S. Tax and Reporting Issues Related to the Use of Foreign Usufructs

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