International Tax

Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax, PLR, Subpart F

IRS: Basis Adjustments Apply to CFC Mid-Year Distributions to Prevent Section 961(b)(2) Gain

By Freeman Law Mar 13, 2023
Cross-Border Tax Insights, Form 3520, International Tax, IRS Collection, Tax Court, Trusts

Taxpayers’ Failure to File Form 3520 and Form 3520-A Results in Extended Statute of Limitations Period: the Cautionary Tale of Fairbank

By Matthew L. Roberts Mar 03, 2023
Attorneys, Cross-Border Tax Insights, International Tax, OVDP, Streamlined Filing

Unreported Foreign Accounts? How to Choose the “Right” International Tax Attorney to Help You

By Matthew L. Roberts Feb 23, 2023
Cross-Border Tax Insights, International Tax

Buying Real Estate in Coastal Mexico: Tax Implications in the U.S. & Mexico

By Stephanie Uribe Feb 07, 2023
Cross-Border Tax Insights, International Tax

Procedimiento simplificado ante el IRS para extranjeros fuera de EUA

By Stephanie Uribe Feb 01, 2023
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Form 5471, International Tax, IRS Disclosure, Offshore Tax, Outbound Transfer, Tax Planning

Reviewing a Foreign Legal Structure

By Freeman Law Jan 24, 2023
Cross-Border Tax Insights, International Tax

Maquiladora Program

By Stephanie Uribe Jan 11, 2023
Cross-Border Tax Insights, International Tax

Tax Residency Status Modification: Mexican Tax Implication

By Stephanie Uribe Dec 15, 2022
Cross-Border Tax Insights, International Tax, Trademarks

U.S. and Mexico | Trademark Royalties and Tax Considerations

By Stephanie Uribe Dec 01, 2022
Cross-Border Tax Insights, International Tax, Withholding

NRA Withholdings—No Guns, Just Taxes

By Freeman Law Nov 21, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, GILTI, International Tax, Participation Exemption, Repatriation, Subpart F, Tax Planning

Strategies to Recharacterize Gain with Untaxed Foreign Earnings.

By Freeman Law Nov 02, 2022
Cross-Border Tax Insights, International Tax

The Methods (and Madness) of Transfer Pricing for Tangible and Intangible Property

By TL Fahring Oct 28, 2022
Cross-Border Tax Insights, Form 926, Gain Recognition Agreement, GRA, International Tax, IRS Disclosure, IRS Regulations, Outbound Stock Transfer, Outbound Transfer, Section 367, Section 6038B, Tax Compliance, Tax Planning

Gain Recognition Agreements and Outbound Stock Transfers

By Freeman Law Oct 19, 2022
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Deductions, GILTI, International Tax, Participation Exemption, Structuring, Subpart F, Tax Planning

Section 245A Overview and Requirements

By Freeman Law Oct 06, 2022
Cross-Border Tax Insights, International Tax, Withholding

International Tax Withholding | Chapter 3 of the Internal Revenue Code

By TL Fahring Oct 03, 2022
Cross-Border Tax Insights, International Tax

Section 965 Tax Installment Payments Are Not Guaranteed

By Freeman Law Sep 20, 2022
International Tax

International Tax Concepts: Tax Residency Status

By Jason B. Freeman Sep 15, 2022
International Tax

Revoking a Mark-to-Market Election with Respect to a Foreign Company

By Jason B. Freeman Sep 11, 2022