The Substantial Presence Test
By Jason B. Freeman
Feb 23, 2022
Purging the PFIC Taint
By Jason B. Freeman
Feb 21, 2022
Federal Income Tax Characterization of Transactions Involving Computer Programs
By TL Fahring
Feb 17, 2022
Private Equity: Offshore Investments and Phantom Income
By Jason B. Freeman
Feb 14, 2022
OECD Issues Model Rules on Nexus and Sourcing
By TL Fahring
Feb 12, 2022
The Tax Court in Brief | TBL Licensing LLC v. Commissioner
By Freeman Law
Feb 11, 2022
The Evolving Standard of “Willfulness” in FBAR Cases: Where are We Now?
By Jason B. Freeman
Feb 10, 2022
Is your Foreign Tax Credit really creditable? Think again: Revisiting the basics of the Foreign Tax Credit
By Fernando Juarez
Feb 01, 2022
Final Regulations on Stock Owned by Domestic Partnerships under Subpart F
By TL Fahring
Jan 29, 2022
Willful FBAR Penalties and a District Court’s Authority to Remand IRS Willful Penalty Computations
By Jason B. Freeman
Jan 26, 2022
Foreign Earned Income Exclusion
By Jason B. Freeman
Jan 26, 2022
The Foreign Tax Credit
By Jason B. Freeman
Jan 18, 2022
A Current “Playoff Picture” of Non-Willful FBAR Violations
By Freeman Law
Jan 03, 2022
ReDISCovering a Tax Classic: The Domestic International Sales Corporation
By TL Fahring
Jan 02, 2022
United States v. Hughes: FBAR Penalties and a Willfulness Roadmap
By Jason B. Freeman
Dec 27, 2021
Challenging FBAR Penalties in Federal Court: FBAR Litigation
By Jason B. Freeman
Dec 17, 2021
Is My Foreign Retirement Account Subject to IRS Information Return Reporting (FBAR, 3520, etc.)?
By Jason B. Freeman
Dec 13, 2021
Why Taxpayers in Louisiana, Texas, and Mississippi Should Consider the IRS’s Streamlined Compliance Procedure Program Now
By Jason B. Freeman
Dec 03, 2021