International Tax

Controlled Foreign Corporation (CFC), Corporate, Cross-Border Tax Insights, Foreign Tax Credit, International Tax, Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | AptarGroup, Inc. v. Comm’r | Foreign Tax Credits and Interest Expense Allocation and Apportionment

By Freeman Law Mar 18, 2022
Cross-Border Tax Insights, International Tax, Tax Treaty

Income Sourcing Rules | Foreign-Source and U.S.-Source Income

By Jason B. Freeman Mar 17, 2022
Cross-Border Tax Insights, FBAR, International Tax, Willfulness

IRS Goes After Holocaust Survivor for Willful FBAR Penalty

By Jason B. Freeman Mar 13, 2022
Cross-Border Tax Insights, International Tax

Foreign Gifts | When Do You Have to Report Them?

By TL Fahring Mar 12, 2022
Cross-Border Tax Insights, International Tax

The Closer-Connection Exception

By Jason B. Freeman Feb 25, 2022
Cross-Border Tax Insights, International Tax, Tax Treaty

Tax Treaty-Based Return Reporting Disclosures

By Jason B. Freeman Feb 24, 2022
Cross-Border Tax Insights, International Tax

The Substantial Presence Test

By Jason B. Freeman Feb 23, 2022
Corporate, Cross-Border Tax Insights, International Tax, PFIC

Purging the PFIC Taint

By Jason B. Freeman Feb 21, 2022
Cross-Border Tax Insights, Data Analytics, International Tax

Federal Income Tax Characterization of Transactions Involving Computer Programs

By TL Fahring Feb 17, 2022
Controlled Foreign Corporation (CFC), Corporate, Cross-Border Tax Insights, International Tax, Private Equity

Private Equity: Offshore Investments and Phantom Income

By Jason B. Freeman Feb 14, 2022
Cross-Border Tax Insights, International Tax

OECD Issues Model Rules on Nexus and Sourcing

By TL Fahring Feb 12, 2022
Corporate, Cross-Border Tax Insights, International Tax, Tax Court, The-Tax-Court-in-Brief Insights

The Tax Court in Brief | TBL Licensing LLC v. Commissioner

By Freeman Law Feb 11, 2022
Cross-Border Tax Insights, FBAR, International Tax

The Evolving Standard of “Willfulness” in FBAR Cases: Where are We Now?

By Jason B. Freeman Feb 10, 2022
Cross-Border Tax Insights, Foreign Tax Credit, International Tax

Is your Foreign Tax Credit really creditable? Think again: Revisiting the basics of the Foreign Tax Credit

By Fernando Juarez Feb 01, 2022
Cross-Border Tax Insights, GILTI, International Tax, Subpart F

Final Regulations on Stock Owned by Domestic Partnerships under Subpart F

By TL Fahring Jan 29, 2022
Cross-Border Tax Insights, FBAR, International Tax

Willful FBAR Penalties and a District Court’s Authority to Remand IRS Willful Penalty Computations

By Jason B. Freeman Jan 26, 2022
Cross-Border Tax Insights, International Tax

Foreign Earned Income Exclusion

By Jason B. Freeman Jan 26, 2022
Cross-Border Tax Insights, Foreign Tax Credit, International Tax

The Foreign Tax Credit

By Jason B. Freeman Jan 18, 2022