Cross-Border Tax Insights

Cross-Border Tax Insights, Foreign Trusts, International Tax

IRS Form 3520 – Reporting Transactions with Foreign Trusts and the Receipt of Foreign Gifts

By Jason B. Freeman Jan 26, 2020
Cross-Border Tax Insights, International Tax

IRS Form 5472

By Jason B. Freeman Jan 14, 2020
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax

IRS Form 5471 – Information Return of U.S. Persons With Respect to Certain Foreign Corporations

By Jason B. Freeman Jan 10, 2020
Cross-Border Tax Insights, FBAR, Fines, International Tax, Penalties

International Reporting Penalties

By Freeman Law Jan 02, 2020
Bank Fraud, Cross-Border Tax Insights, Evasion, FBAR, Fines, Fraud, International Tax

Where Is the Limit on Penalties for Willful FBAR Violations?

By Freeman Law Dec 23, 2019
Cross-Border Tax Insights, FBAR, International Tax

The Recent FBAR Case Allows Multiple Penalties for Single Failure to File FBAR

By Jason B. Freeman Jul 16, 2019
Cross-Border Tax Insights, International Tax, Tax Evasion, White-Collar Defense Insights

International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

By Jason B. Freeman Jun 10, 2019
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, GILTI, International Tax, Tax Reform

Advising International Business Ventures: “Tested Income” under GILTI

By Jason B. Freeman Mar 07, 2019
Controlled Foreign Corporation (CFC), Corporate, Cross-Border Tax Insights, International Tax, Tax Reform

U.S. Shareholder: Changes Under the TCJA

By Jason B. Freeman Feb 21, 2019
Cross-Border Tax Insights, International Tax, Tax Reform

Advising International Business Ventures: Tax Reform’s Section 245A Participation Exemption Regime

By Jason B. Freeman Feb 11, 2019
Cross-Border Tax Insights, International Tax, Tax Reform

Second Installment: Advising International Business Ventures: Tax Reform’s “Transition” Tax

By Jason B. Freeman Feb 01, 2019
Cross-Border Tax Insights, International Tax, Tax Reform

Advising International Business Ventures: Tax Reform’s “Transition” Tax

By Jason B. Freeman Jan 27, 2019
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, GILTI, International Tax, Tax Reform

Advising International Business Ventures: Tax Reform’s New GILTI Tax

By Jason B. Freeman Jan 14, 2019
Cross-Border Tax Insights, International Tax, PFIC

Advising International Business Ventures: Passive Foreign Investment Companies (PFICs)

By Jason B. Freeman Jan 05, 2019
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax

Advising International Business Ventures: Controlled Foreign Corporations and Subpart F

By Jason B. Freeman Dec 30, 2018
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax, Participation Exemption, Tax Reform

Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System

By Jason B. Freeman Dec 26, 2018
Cross-Border Tax Insights, FBAR, Penalties

The Willful FBAR Penalty: Bedrosian and New Insights

By Jason B. Freeman Dec 24, 2018
Cross-Border Tax Insights, FATCA, International Tax, White-Collar Defense Insights

International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

By Jason B. Freeman Nov 05, 2018