International Tax

Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax, Participation Exemption, Tax Reform

Advising International Business Ventures: Tax Reform and a Quasi-Territorial Tax System

By Jason B. Freeman Dec 26, 2018
Cross-Border Tax Insights, FATCA, International Tax, White-Collar Defense Insights

International Tax Enforcement: The Joint Chiefs of Global Tax Enforcement

By Jason B. Freeman Nov 05, 2018
Bank Secrecy Act, FBAR, International Tax, Penalties, Willfulness

FBAR Penalty Update

By Jason B. Freeman Oct 24, 2018
Cross-Border Tax Insights, International Tax, Offshore Tax, Partnership Tax, Tax Reform

New Changes Are Coming to Partnership Withholding

By Freeman Law Aug 01, 2018
Cross-Border Tax Insights, International Tax, S Corporations, Tax Reform

The IRS Announces New “Compliance Campaigns:” Unreported Virtual Currency, S-Corporation Compliance, and International Tax Enforcement Are Top Priorities

By Jason B. Freeman Jul 13, 2018
Cross-Border Tax Insights, FBAR, International Tax

Another FBAR Penalty Case Demonstrates the Perils of Failing to Report a Foreign Account

By Jason B. Freeman Jun 16, 2018
Cross-Border Tax Insights, FBAR, International Tax

The Colliot Decision: The Government Loses an FBAR Case that May Change International Reporting Penalties

By Jason B. Freeman Jun 05, 2018
Cross-Border Tax Insights, International Tax, Tax Reform

From Worldwide to Territorial, What Does It All Mean?

By Freeman Law May 31, 2018
Cross-Border Tax Insights, International Tax, Offshore Tax

20/22 Vision – Tax Consequences for Puerto Rico

By Freeman Law May 26, 2018
Cross-Border Tax Insights, International Tax, Tax Reform

The Section 965 Transition Tax

By Jason B. Freeman May 22, 2018
Cross-Border Tax Insights, FATCA, FBAR, International Tax, Offshore Tax, OVDP

The Paradise Papers Continue to Shed Light on the Use of Offshore Tax Havens

By Freeman Law Apr 18, 2018
Cross-Border Tax Insights, International Tax, OVDP, Streamlined Filing

Last Call: The Offshore Voluntary Disclosure Program to End

By Jason B. Freeman Mar 17, 2018
Cross-Border Tax Insights, International Tax

Determining the Enforceability of a Section 6038A Summons

By Freeman Law Sep 20, 2017
Cross-Border Tax Insights, International Tax, Tax Litigation Insights

Summoning Foreign Records: The Section 6038A Summons

By Freeman Law Sep 13, 2017
Cross-Border Tax Insights, FATCA, International Tax

Court Finds Senator Rand Paul and Co-Plaintiffs Lacked Standing to Challenge Foreign Account Reporting Rules

By Jason B. Freeman Aug 30, 2017
Cross-Border Tax Insights, FBAR, International Tax, Streamlined Filing

Non-US Residents May Still Be Subject to FBAR Reporting Guidelines

By Freeman Law Jun 12, 2017
Cross-Border Tax Insights, International Tax, IRS Regulations, Offshore Tax

Foreign-Owned Domestic Disregarded Entities: The New Reporting Requirements

By Jason B. Freeman Apr 27, 2017
Audit, Cross-Border Tax Insights, International Tax, Offshore Tax, OVDP, Streamlined Filing

An Update on International Tax Enforcement

By Jason B. Freeman Mar 14, 2017