Purging the PFIC Taint

Federal Income Tax Characterization of Transactions Involving Computer Programs

Private Equity: Offshore Investments and Phantom Income

OECD Issues Model Rules on Nexus and Sourcing

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

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

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

Final Regulations on Stock Owned by Domestic Partnerships under Subpart F

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

Foreign Earned Income Exclusion

The Foreign Tax Credit

A Current “Playoff Picture” of Non-Willful FBAR Violations

ReDISCovering a Tax Classic: The Domestic International Sales Corporation

United States v. Hughes: FBAR Penalties and a Willfulness Roadmap

Challenging FBAR Penalties in Federal Court: FBAR Litigation

Is My Foreign Retirement Account Subject to IRS Information Return Reporting (FBAR, 3520, etc.)?

Why Taxpayers in Louisiana, Texas, and Mississippi Should Consider the IRS’s Streamlined Compliance Procedure Program Now

The Tax Risk of a Permanent Establishment