In this week’s blog, we discuss a recent Supreme Court decision upholding the constitutionality of the Section 965 transition tax, which was imposed at the end of 2017. We also discuss the impact the…
Read MoreIn a recent blog, the National Taxpayer Advocate (NTA) Erin Collins made several critical observations of the IRS’s penalty process, particularly with respect to foreign information penalties.
Read MoreIn a surprising decision last year, the U.S. Tax Court, in Farhy v. Commissioner, 160 T.C, No. 6 (April 3, 2023), held that the IRS lacks the statutory authority to assess certain Form 5471…
Read MoreIn this week’s blog, we review the U.S. tax rules relating to the payment of alimony, both from a domestic law and a treaty law perspective.
Read MoreIn a recent intriguing decision, the U.S. District Court for the Southern District of California tackled the issue of whether a taxpayer is required to file an FBAR if he has the status of a non-US…
Read MoreFor US expats with businesses abroad, it’s important to understand the US tax implications of your business structuring and operations.
Read MoreAccording to the latest Treasury Department figures, the number of people who expatriated from the U.S. jumped nearly 45% during the fourth quarter of 2023 compared with the previous quarter.
Read MoreIn a recent intriguing decision, the U.S. Court of Federal Claims tackled the issue of whether the provisions of an applicable U.S. tax treaty can be used to allow a foreign tax credit (“FTC”) to…
Read MoreIn this week’s blog, we do a case review of a district court decision involving FBAR instructions and penalties. The case joins a line of decisions addressing the scope and parameters of the FBAR…
Read MoreNonresident aliens (i.e., noncitizen nonresidents of the United States) who hold U.S. assets should think carefully about the U.S. estate tax implications.
Read MoreWhile many tax figures, such as exclusions or penalties, remain the same from year to year, there are certain numbers that are adjusted typically on annual basis, taking into account inflation and…
Read MoreIn previous blogs, we’ve discussed some of the basics of PFIC ownership, including PFIC reporting, PFIC elections, and whether gifts are subject to the PFIC rules.
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