Tax Court in Brief | AptarGroup, Inc. v. Comm’r | Foreign Tax Credits and Interest Expense Allocation and Apportionment
By Freeman Law
Mar 18, 2022
Income Sourcing Rules | Foreign-Source and U.S.-Source Income
By Jason B. Freeman
Mar 17, 2022
IRS Goes After Holocaust Survivor for Willful FBAR Penalty
By Jason B. Freeman
Mar 13, 2022
Foreign Gifts | When Do You Have to Report Them?
By TL Fahring
Mar 12, 2022
The Closer-Connection Exception
By Jason B. Freeman
Feb 25, 2022
Tax Treaty-Based Return Reporting Disclosures
By Jason B. Freeman
Feb 24, 2022
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