EPIC: “Fails charges” guidance provided by IRS
Which sovereign jurisdiction can tax an item of income? This eternal question arises whenever Wall Street creates a new financial product involving multinational parties. For “fails charges,” the...
View ArticleThe Internal Revenue Code and the Infield Fly Rule
In honor of tomorrow’s opening day festivities, I give you my favorite Law Review article ever....
View ArticleWhen do I become a US “estate tax” resident? The shocking truth revealed!
Well, maybe it’s not “shocking,” but it may be a bit surprising. Last week, we discussed the estate tax planning benefits of “drop off” trusts for incoming foreign nationals. One major point to...
View ArticleForeign partner? Read this.
On June 22, IRS announced new changes to its procedures for issuing individual taxpayer identification numbers (ITINs). So, what’s an ITIN? ITIN literally stands for Individual Tax Identification...
View ArticleThe dramatic tale of “A True FBAR Criminal”
One question I often hear when explaining FBAR liability is, “Are they really going to come after me?” It’s not an unreasonable question. Oftentimes, the penalties for FBAR non-compliance can seem...
View ArticleForget the Olympics; Boycott This!
Pop Quiz: what do Iraq, Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, the UAE, and Yemen have in common? Exemplary human rights record? Demonstrated historic dedication to religious tolerance?...
View ArticleMr. Tax Lawyer goes to Washington
I’ll admit it. I’m a mark for Capra films. I cheer for every ulcer Grandpa gives the IRS agent. I cry every Christmas Eve when Clarence gets his wings. And like Mr. Smith, I’ve always wanted to go to...
View ArticleAn unpleasant surprise for expat family members: A look at Section 2801
Are you a family member or friend of an expat? Get ready to be surprised! I always hated surprises. Actually, that’s not quite right. I love being truly surprised. Its terrific when someone actually...
View ArticleIRS slooooowwwlllly acknowledging electronic docs; Supreme Court takes on...
“Can you just scan that to me?” If you’re like me, a “no” response to the above question generates nothing short incredulity, animosity, and exasperation. At times, it can seem there is no logic as...
View ArticleThe Internal Revenue Code and the Infield Fly Rule
In honor of tomorrow’s opening day festivities, I give you my favorite Law Review article ever....
View Article
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