International Tax

Cross-Border Tax Insights, Foreign Trusts, Form 3520, International Tax

The IRS Issues Significant Guidance on Foreign Trusts: Forms 3520 and Form 3520-A

By Jason B. Freeman Mar 04, 2020
Cross-Border Tax Insights, Gift & Estate Tax, International Tax, Penalties, Trust

Form 3520-A, Information Return of Foreign Trusts With a U.S. Owner

By Jason B. Freeman Feb 27, 2020
Cross-Border Tax Insights, Fraud, International Tax, Offshore Tax, Voluntary Disclosure

The J5 Continues its Efforts to Identify International Tax Cheats

By Jason B. Freeman Feb 21, 2020
Cross-Border Tax Insights, International Tax, Offshore Tax, Voluntary Disclosure

The Swiss Bank Program: Civil and Criminal Risk for Offshore Account Holders

By Freeman Law Feb 16, 2020
Cross-Border Tax Insights, International Tax, Streamlined Filing, Voluntary Disclosure

The Updated IRS Voluntary Disclosure Program

By Freeman Law Feb 12, 2020
Cross-Border Tax Insights, International Tax, Partnership

Form 8865, U.S. Persons and Foreign Partnerships

By Jason B. Freeman Feb 06, 2020
Criminal, Cross-Border Tax Insights, Cryptocurrency, International Tax, Tax Fraud

Doctor Sentenced to 30 Months in Prison for Filing False Income Tax Return Involving Offshore Assets and Cryptocurrency

By Jason B. Freeman Jan 28, 2020
Cross-Border Tax Insights, Foreign Trusts, International Tax

IRS Form 3520 – Reporting Transactions with Foreign Trusts and the Receipt of Foreign Gifts

By Jason B. Freeman Jan 26, 2020
Cross-Border Tax Insights, International Tax

IRS Form 5472

By Jason B. Freeman Jan 14, 2020
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax

IRS Form 5471 – Information Return of U.S. Persons With Respect to Certain Foreign Corporations

By Jason B. Freeman Jan 10, 2020
Cross-Border Tax Insights, FBAR, Fines, International Tax, Penalties

International Reporting Penalties

By Freeman Law Jan 02, 2020
Bank Fraud, Cross-Border Tax Insights, Evasion, FBAR, Fines, Fraud, International Tax

Where Is the Limit on Penalties for Willful FBAR Violations?

By Freeman Law Dec 23, 2019
Cross-Border Tax Insights, FBAR, International Tax

The Recent FBAR Case Allows Multiple Penalties for Single Failure to File FBAR

By Jason B. Freeman Jul 16, 2019
Cross-Border Tax Insights, International Tax, Tax Evasion, White-Collar Defense Insights

International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

By Jason B. Freeman Jun 10, 2019
Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, GILTI, International Tax, Tax Reform

Advising International Business Ventures: “Tested Income” under GILTI

By Jason B. Freeman Mar 07, 2019
Controlled Foreign Corporation (CFC), Corporate, Cross-Border Tax Insights, International Tax, Tax Reform

U.S. Shareholder: Changes Under the TCJA

By Jason B. Freeman Feb 21, 2019
Cross-Border Tax Insights, International Tax, Tax Reform

Advising International Business Ventures: Tax Reform’s Section 245A Participation Exemption Regime

By Jason B. Freeman Feb 11, 2019
Cross-Border Tax Insights, International Tax, Tax Reform

Second Installment: Advising International Business Ventures: Tax Reform’s “Transition” Tax

By Jason B. Freeman Feb 01, 2019