International Tax

Cross-Border Tax Insights, Foreign Tax Credit, International Tax

The Foreign Tax Credit

By Jason B. Freeman Jan 18, 2022
Cross-Border Tax Insights, FBAR, International Tax

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

By Freeman Law Jan 03, 2022
Corporate, Cross-Border Tax Insights, International Tax

ReDISCovering a Tax Classic: The Domestic International Sales Corporation

By TL Fahring Jan 02, 2022
Cross-Border Tax Insights, FBAR, International Tax

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

By Jason B. Freeman Dec 27, 2021
Cross-Border Tax Insights, FBAR, International Tax

Challenging FBAR Penalties in Federal Court: FBAR Litigation

By Jason B. Freeman Dec 17, 2021
Cross-Border Tax Insights, International Tax, Streamlined Filing, Voluntary Disclosure

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

By Jason B. Freeman Dec 13, 2021
Cross-Border Tax Insights, FBAR, International Tax, Streamlined Filing

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

By Jason B. Freeman Dec 03, 2021
Cross-Border Tax Insights, International Tax, Tax Treaty

The Tax Risk of a Permanent Establishment

By Jason B. Freeman Nov 18, 2021
Cross-Border Tax Insights, International Tax

Tax Controversies After BEPS

By Fernando Juarez Nov 17, 2021
Cross-Border Tax Insights, FBAR, International Tax

Beware of Your FBAR Obligations | U.S. v. Solomon

By Freeman Law Nov 16, 2021
Cross-Border Tax Insights, International Tax

“It Depends”—Knowledge and Overpayment Interest Accrual on International Withholding Refund Claims

By TL Fahring Nov 15, 2021
Cross-Border Tax Insights, FBAR, International Tax

Federal Court Orders Taxpayer to Repatriate Assets to Satisfy FBAR Penalty Judgment

By Jason B. Freeman Nov 14, 2021
Cross-Border Tax Insights, FIRPTA, International Tax

The Foreign Investment in Real Property Tax Act (“FIRPTA”)

By Jason B. Freeman Nov 09, 2021
Cross-Border Tax Insights, FIRPTA, International Tax

The FIRPTA Withholding Obligation

By Jason B. Freeman Nov 01, 2021
Cross-Border Tax Insights, International Tax, Tax Treaty

Tax Treaties

By Jason B. Freeman Oct 29, 2021
Cross-Border Tax Insights, International Tax, Tax Treaty

Competent Authority and Double Taxation

By Jason B. Freeman Oct 28, 2021
Cross-Border Tax Insights, FBAR, International Tax

What is the Difference Between Willful and Non-Willful Conduct for FBAR Penalties: The Hughes Decision Provides Some Clarity

By Jason B. Freeman Oct 27, 2021
Cross-Border Tax Insights, FBAR, FinCEN, International Tax

Form 8938 and FinCEN Form 114 Compared

By Jason B. Freeman Oct 26, 2021