International Tax

Controlled Foreign Corporation (CFC), International Tax, Tax Court

Flume II: The Tax Court’s Recent Decision Involves UBS of Switzerland and Controlled Foreign Corporations

by Jason B. Freeman / Jun 15, 2020 2729
International Tax, Penalties

Everything That You Need To Know About International Tax Penalties

by Jason B. Freeman / Jun 08, 2020 2645
International Tax, Offshore Tax

U.S. Government Continues To Crack Down On Unreported Offshore Bank Accounts

by Jason B. Freeman / May 24, 2020 2478
International Tax

IRS Private Letter Ruling Allows Foreign LLC’s Late Entity-Classification Election

by Jason B. Freeman / May 06, 2020 2350
Form 5471, International Tax

IRS Private Letter Ruling Allows Foreign Corporation’s Untimely Form 5471 Election

by Jason B. Freeman / May 04, 2020 2348
International Tax

United States Ranks Second as Financial Secrecy Haven, Beating Out Switzerland

by Freeman Law / Apr 28, 2020 2241
International Tax, Voluntary Disclosure

The Danger of a Quiet Disclosure

by Ryan Dean / Apr 19, 2020 2220
International Tax, Voluntary Disclosure

The Government’s Warning to Taxpayers: False Certifications of Non-willfulness Will Be Prosecuted

by Ryan Dean / Apr 15, 2020 2203
Criminal, International Tax, White Collar

International Taxes and Crimes: The “Revenue Rule,” RICO, and Wire Fraud

by Jason B. Freeman / Apr 13, 2020 2191
FBAR, International Tax, OVDP

Recent FBAR Case: Signing and Not Reading Tax Return Leads to $900,000 Penalty

by Jason B. Freeman / Mar 12, 2020 1616