Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

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  1. Two New 304 Transaction Charts
    October 11, 2026
  2. In the Tax Court & at the IRS Last Month --- September 2026
    October 2, 2026
  3. Upcoming U.S. Sourcing Rules Presentations
    September 28, 2026
  4. Classifying CDP Opinions
    September 26, 2026
  5. In the Tax Court & at the IRS Last Month --- August 2026
    September 1, 2026
  6. Bruyea & Christensen Reversed - No FTC for NIIT
    September 1, 2026
  7. Enrolled Agents By Country and By State (August 2026)
    August 27, 2026
  8. Tax Authorities Search
    August 25, 2026
  9. In the Tax Court & at the IRS Last Month --- July 2026
    August 13, 2026
  10. Expatriations Are on the Rise Again (2026 2nd Quarter Published Expatriates)
    July 22, 2026
  11. Chart of PLR 202629003 (Late Relief for FIRPTA Withholding Certificate)
    July 20, 2026
  12. Graph of Number of Disciplined Tax Professionals
    July 8, 2026
  13. FIRPTA Withholding by the Buyer Is Generally Required
    July 3, 2026
  14. In the Tax Court & at the IRS Last Month --- June 2026
    July 2, 2026
  15. IRS Removes Delinquent FBAR Submission Procedures
    July 1, 2026
  16. Filtered List of Overseas Tax Preparers
    June 25, 2026
  17. In the Tax Court & at the IRS Last Month --- May 2026
    June 5, 2026
  18. 57 U.S. Income Tax Treaties
    May 30, 2026
  19. Tax Court Opinion Search
    May 27, 2026
  20. IRS Treaty Table 3: List of Tax Treaties - Portugal Protocol
    May 6, 2026
  21. Chart of PLR 202611004 (865(h)(2)(A) Election for Sale of Indian Stock)
    May 3, 2026
  22. In the Tax Court & at the IRS Last Month --- April 2026
    May 2, 2026
  23. 2026 1st Quarter Published Expatriates - Trending Up
    April 21, 2026
  24. Section 911 Housing Cost Amounts Updated for 2026
    April 7, 2026
  25. Section 987 Equity and Basis Pool Method Calculator
    April 7, 2026
  26. In the Tax Court & at the IRS Last Month --- March 2026
    April 2, 2026
  27. Chart of PLR 202613004 (865(h)(2)(A) Election)
    March 28, 2026
  28. Number of Chief Counsel Advice Emails
    March 24, 2026
  29. Update to Classification of Transactions Chart (Waterman Steamship, etc.)
    March 7, 2026
  30. Chart of PLR 202607002 (Treaty Rate for BPT With U.S. LLC)
    March 4, 2026
  31. Tax Court Corrects It's Budget Justification
    March 1, 2026
  32. In the Tax Court & at the IRS Last Month --- February 2026
    March 1, 2026
  33. Famous Tax Quotes - Fabricated Case Citations (AI Hallucinations)
    February 11, 2026
  34. Tax Court Again Overstates Number of Opinions Issued
    February 10, 2026
  35. Exchange Rates for 2025
    February 10, 2026
  36. Court Listener - Citation Lookup for Tax-Related Opinions
    February 6, 2026
  37. In the Tax Court & at the IRS Last Month --- January 2026
    February 3, 2026
  38. 2025 4th Quarter Published Expatriates (2% Increase Year-Over-Year)
    January 22, 2026
  39. PFIC Calculator (Sales & Distributions)
    January 20, 2026
  40. Tax Court Number of Pages / Tokens Analysis
    January 8, 2026
  41. The Case of C.M. and the Border Run (Poem, AI Assist Generated)
    January 7, 2026
  42. IRS Table 3. List of Tax Treaties Has Been Updated
    January 7, 2026
  43. Chart of PLR 202551006 (Outbound 351 of Built-In Loss Property)
    January 5, 2026
  44. 2025 Stats - Tax Court Opinion Release Patterns
    January 1, 2026
  45. 2025 Stats - Pro Se Opinions in the Tax Court
    January 1, 2026
  46. 2025 Stats - Opinions Cited To By the Tax Court
    January 1, 2026
  47. 2025 Stats - Code Sections Cited To By the Tax Court
    January 1, 2026
  48. 2025 Stats - Tax Court Opinions By Year
    January 1, 2026
  49. 2025 Stats - Tax Court Opinions By Judge
    January 1, 2026
  50. 2025 Stats - Pages in the Internal Revenue Bulletin Decrease By 23%
    January 1, 2026
  51. 2025 Stats - IRS Written Determinations Increase By 10%
    January 1, 2026
  52. In the Tax Court & at the IRS Last Month --- December 2025
    January 1, 2026
  53. 2026 PLR Fees For 9100 Relief Remain the Same
    December 26, 2025
  54. Chart of Example in Notice 2025-77
    December 20, 2025
  55. Effective Tax Rate Calculations for Check the Box Analysis
    December 17, 2025
  56. Famous Tax Quotes - Tax Planning Is As American As Apple Pie
    December 13, 2025
  57. Sourcing of Income Quiz
    December 10, 2025
  58. Enrolled Agents In India Increase By Nearly 1,000
    December 7, 2025
  59. In the Tax Court & at the IRS Last Month --- November 2025
    December 1, 2025
  60. Corporate Tax Quiz
    November 22, 2025
  61. 2025 3rd Quarter Published Expatriates - Higher Than Typical
    November 14, 2025
  62. You Don't Usually See Cites to Wrong Code Sections in Tax Court Cases
    November 14, 2025
  63. Famous Tax Quotes - Congressionally Induced Transactions
    November 13, 2025
  64. In the Tax Court & at the IRS Last Month --- October 2025
    November 3, 2025
  65. Attorneys Must Represent Estates Before the Court of Federal Claims (Sovereign Citizen)
    October 23, 2025
  66. PTIN Names and Contact Info
    October 20, 2025
  67. 2026 Inflation Adjustments for Individuals in the International Tax Arena
    October 12, 2025
  68. In the Tax Court & at the IRS Last Month --- September 2025
    October 4, 2025
  69. More IRS Treaty Documents
    October 3, 2025
  70. Chart of 3M Company v. Commr. (IRS Loses)
    October 2, 2025
  71. The "Saving Clause"
    September 25, 2025
  72. Chart of AM 2025-002 (BPT Treaty Relief for Rev. Hybrid Entity With US Branch)
    September 21, 2025
  73. Semantic Search - Thinking Out Loud
    September 19, 2025
  74. In the Tax Court & at the IRS Last Month --- August 2025
    September 19, 2025
  75. Times Are A-Changing - TaxProf Blog Is Ending
    September 16, 2025
  76. IRS Treaty Documents Are Slowly Improving
    September 15, 2025
  77. IRS Publishes Technical Explanations to 1971 Norway Treaty and 1980 Norway Protocol
    September 6, 2025
  78. In the Tax Court & at the IRS Last Month --- July 2025
    August 13, 2025
  79. Self-Employed Abroad
    August 7, 2025
  80. 2025 2nd Quarter Published Expatriates
    July 30, 2025
  81. Notes on the OBBB
    July 27, 2025
  82. In the Tax Court & at the IRS Last Month --- June 2025
    July 1, 2025
  83. Guide to Tax Court Docket Suffixes
    June 30, 2025
  84. In the Tax Court & at the IRS Last Month --- May 2025
    June 17, 2025
  85. Free Flowchart - Section 2040: Portion of Jointly Owned Property to Include in Gross Estate
    May 27, 2025
  86. Hawaiian Philippine Added to Classification of Transactions Chart
    May 24, 2025
  87. You Can"t Rely on a Tax Opinion When the Opinion Writer Says It Is Hogwash
    May 16, 2025
  88. Elections Related to Foreign Taxes
    May 16, 2025
  89. IRS Publishes Technical Explanation to 1974 Polish Treaty
    May 8, 2025
  90. In the Tax Court & at the IRS Last Month --- April 2025
    May 7, 2025
  91. Tax Court Again Overstates Number of Opinions Issued
    May 3, 2025
  92. 2 New IRS Practice Units
    May 2, 2025
  93. Famous Tax Quotes - A Multiplier of 54 and Fantastical Numbers
    May 1, 2025
  94. 2025 1st Quarter Published Expatriates
    April 23, 2025
  95. Famous Tax Quotes - Garden Variety Negligence
    April 19, 2025
  96. 6 New IRS Practice Units
    April 17, 2025
  97. Famous Tax Quotes - We Can't Just Guess
    April 11, 2025
  98. In the Tax Court & at the IRS Last Month --- March 2025
    April 10, 2025
  99. 3 New IRS Practice Units
    April 9, 2025
  100. IRS Denies Indirect Foreign Tax Credits For Failure to Attach Code §962 Election Statement
    April 8, 2025
  101. 2 New IRS Practice Units
    April 4, 2025
  102. 5 New IRS Practice Units
    April 2, 2025
  103. Number of Chief Counsel Advice Emails
    March 28, 2025
  104. In the Tax Court & at the IRS Last Month --- February 2025
    March 26, 2025
  105. 8 New IRS Practice Units
    March 25, 2025
  106. Tax Court Summary Opinions - Average of 83 Percent of Pro Se Opinions
    March 12, 2025
  107. Percentage of Pro Se Opinions in the Tax Court (2001 to 2024)
    March 10, 2025
  108. Zip Codes Updated and Enhanced for 2022 Data
    March 4, 2025
  109. Filtering of TaxProf Blog Posts
    February 12, 2025
  110. Famous Tax Quotes - Nailing Jello to a Wall
    February 10, 2025
  111. 2024 IRS Tax Forum PowerPoints
    February 6, 2025
  112. In the Tax Court & at the IRS Last Month --- January 2025
    February 4, 2025
  113. 2024 Expatriations Increase by 48%
    January 31, 2025
  114. Three New FTC Practice Units
    January 30, 2025
  115. IRS Tax Exempt Determination Letters Are Not Searchable (They Should Be)
    January 29, 2025
  116. In the Tax Court & at the IRS Last Month --- December 2024
    January 28, 2025
  117. There Are a Lot of Enrolled Agents in California (Heat Map)
    January 27, 2025
  118. Number of Tax Court Opinions Issued By Active Status Judges in 2024
    January 12, 2025
  119. Exchange Rates for 2024
    January 9, 2025
  120. Supreme & Appellate Court Opinions Cited By the Tax Court in 2024
    January 1, 2025
  121. 2025 PLR Fees For 9100 Relief Increase By 15%
    December 29, 2024
  122. A Record Number of Pages Published in the Internal Revenue Bulletin for 2024
    December 28, 2024
  123. AM 2024-005 - Source of Gain From Certain Dispositions of Stock
    December 21, 2024
  124. Review of An IRS-Prepared Form 5471
    December 19, 2024
  125. PLR 199914006 - An LLC With 2 Members Was A Disregarded Entity
    December 19, 2024
  126. PLR 200923001 (now revoked) - Domestically Controlled REIT
    December 18, 2024
  127. PLR 201451009 - Professional Corps Ruled Part Of Affiliated Group
    December 10, 2024
  128. IRS Removes Inaccurate Version of the Swedish Treaty
    December 7, 2024
  129. Video on Reporting Rules for UK SIPPs
    December 6, 2024
  130. Newly Released Treaty Documents
    December 6, 2024
  131. In the Tax Court & at the IRS Last Month --- November 2024
    December 4, 2024
  132. Lawsky Practice Problems
    December 2, 2024
  133. FICA and Self-Employment Tax For Salaries Paid By a Foreign DRE
    November 17, 2024
  134. Rev. Rul. 84-79 - Shares Owned Through a Revocable Voting Trust
    November 16, 2024
  135. Tax Court Overstates Number of Opinions Issued In Report to Congress (again)
    November 14, 2024
  136. Rev. Rul. 77-467 - Redemption With Waiver of Family Attribution & Rental of Real Estate
    November 7, 2024
  137. Beneficial Ownership Controls For Consolidated Returns (Miami National Bank)
    November 6, 2024
  138. More on Classifying Transactions
    November 5, 2024
  139. Famous Tax Quotes - Rococo Fugue & Baroque Fugue
    November 3, 2024
  140. In the Tax Court & at the IRS Last Month --- October 2024
    November 2, 2024
  141. 2024 3rd Quarter Published Expatriates - Highest In 4 Years
    October 28, 2024
  142. Distribution of Own Debt As a Dividend (Kraft Foods)
    October 27, 2024
  143. Famous Tax Quotes - Five "Any's" In One Sentence
    October 23, 2024
  144. 2025 Inflation Adjustments for Individuals in the International Tax Arena
    October 22, 2024
  145. Rev. Rul. 75-512 - Redemption Not Equivalent to a Dividend Under 302(b)(1)
    October 20, 2024
  146. Rev. Rul. 70-469 - Nominal Ownership - Affiliated Group Definition
    October 19, 2024
  147. Passive Income For Less Than 10% Limited Partner (Chart)
    October 13, 2024
  148. In the Tax Court & at the IRS Last Month --- September 2024
    October 4, 2024
  149. Rev. Rul. 76-19 - Canadian Corp With Employees In the U.S.
    October 1, 2024
  150. CFC Overlap Rule to Avoid PFIC Classification (PLR 200943004 & Reg. 1.958-1(d))
    September 30, 2024
  151. Famous Tax Quotes - A Slender Reed
    September 27, 2024
  152. Captive Insurance Companies Can Have A Disastrous Tax Result (CCA 202422010)
    September 23, 2024
  153. Enrolled Agents By Country (September 2024)
    September 21, 2024
  154. "Principals" as Partners in a Partnership
    September 16, 2024
  155. No 245A DRD for Dividends from a SFC to a CFC
    September 12, 2024
  156. In the Tax Court & at the IRS Last Month --- August 2024
    September 1, 2024
  157. Where Is the GILTI High-Tax Exception?
    August 30, 2024
  158. In the Tax Court & at the IRS Last Month --- July 2024
    August 21, 2024
  159. Update to Chart - Classification of Transactions
    August 15, 2024
  160. 2024 2nd Quarter Published Expatriates
    July 31, 2024
  161. New Resource Page - Certain High Thresholds
    July 25, 2024
  162. Famous Tax Quotes - Does Not Pass the Smell Test
    July 16, 2024
  163. In the Tax Court & at the IRS Last Month --- June 2024
    July 5, 2024
  164. Famous Tax Quotes - Shoebox Method
    June 10, 2024
  165. In the Tax Court & at the IRS Last Month --- May 2024
    June 2, 2024
  166. Deciphering Tax Court Opinion Release Patterns
    May 30, 2024
  167. Four New Charts
    May 26, 2024
  168. In the Tax Court & at the IRS Last Month --- April 2024
    May 16, 2024
  169. 2024 1st Quarter Published Expatriates
    May 1, 2024
  170. Chart for the Tax Court Case of PICCIRC, LLC --- Disguised Sale & Partnership Shams
    April 23, 2024
  171. Famous Tax Quotes - The Proof of the Pudding is in the Eating
    April 21, 2024
  172. In the Tax Court & at the IRS Last Month --- March 2024
    April 1, 2024
  173. Section 911 Housing Cost Amounts Updated for 2024
    March 21, 2024
  174. In the Tax Court Last Month --- February 2024
    March 6, 2024
  175. Enrolled Agents Per Million People By State
    March 3, 2024
  176. Enrolled Agents By Country (September 2023)
    February 25, 2024
  177. Famous Tax Quotes - A Conjurer"s Circle
    February 20, 2024
  178. Famous Tax Quotes - Must Timely File Using The Best Information Available
    February 11, 2024
  179. Famous Tax Quotes - Insurance Premiums Were Nonsense
    February 4, 2024
  180. Tax Court Statistics - 2023
    January 27, 2024
  181. 2023 4th Quarter Published Expatriates
    January 26, 2024
  182. Exchange Rates for 2023
    January 9, 2024
  183. Pages Published by the IRS in 2023 (in the Federal Register & in the IRB)
    January 8, 2024
  184. IRS Written Determinations Increased By 4% In 2023
    January 2, 2024
  185. 2024 PLR Fees For 9100 Relief Remain the Same
    December 30, 2023
  186. Videos Published in 2023
    December 27, 2023
  187. Situational Charts Published in 2023
    December 22, 2023
  188. Famous Tax Quotes - A Bundle of Sticks
    December 17, 2023
  189. Top 8 Appellate Court Cases Cited by the Tax Court
    December 11, 2023
  190. Top 10 Supreme Court Cases Cited by the Tax Court
    December 4, 2023
  191. New IRS Practice Unit - Taxation of Beneficiary of a Foreign Non-Grantor Trust
    December 1, 2023
  192. Famous Tax Quotes - Tweedledum and Tweedledee
    November 19, 2023
  193. Famous Tax Quotes - Congress Does Not Hide Elephants In Mouseholes
    November 18, 2023
  194. Regular Expressions in the Tax World
    November 10, 2023
  195. 2024 Inflation Adjustments for Individuals in the International Tax Arena
    November 9, 2023
  196. 2023 3rd Quarter Published Expatriates
    October 27, 2023
  197. Famous Tax Quotes - Hard To See Duress Without Any IRS Interaction
    October 15, 2023
  198. Tax Court Judge Lauber Is a Rock Star
    September 20, 2023
  199. New situational charts published today
    September 11, 2023
  200. 2023 2nd Quarter Published Expatriates
    July 20, 2023
  201. New IRS Practice Unit: Expatriation – Mark-to-Market Tax Regime
    July 13, 2023
  202. New IRS Practice Unit - FTC - Categorization of Income and Taxes Into Proper Basket
    June 27, 2023
  203. Zip Codes Updated for 2020 Data
    June 3, 2023
  204. Famous Tax Quotes - Confusing the Terms "Petitioner" and "Respondent"
    May 19, 2023
  205. Three New IRS Practice Units - 267(a)(3), 385, and 163(j) for CFCs
    May 18, 2023
  206. Treaty Updates Page
    May 15, 2023
  207. Famous Tax Quotes - Bargaining For Tax Benefits
    April 19, 2023
  208. 2023 1st Quarter Published Expatriates
    April 18, 2023
  209. Famous Tax Quotes - Tax Laws Should Be Intelligible
    April 4, 2023
  210. The IRS Publishes Far Fewer PLRs Than It Used To
    March 31, 2023
  211. 4,000 Tax Cases and Rulings
    March 27, 2023
  212. 3 New Videos – PFIC With No QEF, Pedigreed QEF, & Unpedigreed QEF
    March 21, 2023
  213. Famous Tax Quotes - The Most Honorable People I Have Ever Dealt With
    March 18, 2023
  214. Section 911 Housing Cost Amounts Updated for 2023
    March 16, 2023
  215. Famous Tax Quotes - Self-serving, Unreliable, Unverified, and Contradicted Testimony
    March 11, 2023
  216. Musings on Structure Planning For Closely-Held Foreign Entities
    March 6, 2023
  217. Famous Tax Quotes - "To tautologize, section 741 applies only where it applies"
    February 17, 2023
  218. IRS Regulations Lowest in 24 Years
    February 13, 2023
  219. Charts Created in 2022
    February 11, 2023
  220. 2022 Published Expatriates Increases By 57%
    January 26, 2023
  221. Exchange Rates for 2022
    January 25, 2023
  222. A Tangled Web of Definitions
    January 4, 2023
  223. ChatGPT – Fun, But Not Yet Serious for Legal Writing
    December 7, 2022
  224. Property of Former US Residents: Owning Stock Through a Partnership
    December 2, 2022
  225. Recent Regulation Packages Related To International Tax
    October 29, 2022
  226. 2022 3rd Quarter Published Expatriates
    October 25, 2022
  227. 2023 Inflation Adjustments for Individuals in the International Tax Arena
    October 20, 2022
  228. New IRS Practice Unit – FBAR (FinCEN Form 114)
    October 19, 2022
  229. How inaccurate is the IRS Version of the Sweden Treaty (pretty inaccurate)
    September 23, 2022
  230. Reviewing Form 5471
    September 9, 2022
  231. 16 New Charts Published
    August 30, 2022
  232. New IRS Practice Unit - IRC 958 Rules for Determining Stock Ownership
    August 30, 2022
  233. 13,000 Regulation Examples
    August 16, 2022
  234. Famous Tax Quotes - One Cannot Distribute What One Does Not Have
    July 28, 2022
  235. 2022 2nd Quarter Published Expatriates
    July 27, 2022
  236. New IRS Practice Unit - 1120-F Delinquent Returns - Filing Deadline Waiver Process
    July 26, 2022
  237. Famous Tax Quotes - Tax Legislation Is Not A Promise
    July 25, 2022
  238. Internet Birthday --- June 26, 2005
    June 26, 2022
  239. Famous Tax Quotes - Turning Square Corners
    June 5, 2022
  240. Recent Web Traffic Data
    May 9, 2022
  241. 2022 1st Quarter Published Expatriates
    April 25, 2022
  242. New IRS Practice Unit - NRA Deferred Compensation
    April 2, 2022
  243. New situational chart and video on Income Classification
    March 29, 2022
  244. Famous Tax Quotes - Congress Did Not Want To Deal With Citizens As If They Were Still In The Nursery
    March 18, 2022
  245. Section 911 Housing Cost Amounts Updated for 2022
    March 9, 2022
  246. Update to Zip Codes App and New Heat Maps
    February 24, 2022
  247. 2021 Published Expatriates Decreases By 64%
    January 25, 2022
  248. 8 New Charts Published
    January 20, 2022
  249. New Flowchart – Section 1202 Exclusion for Qualified Small Business Stock ("QSBS")
    January 18, 2022
  250. Five New IRS Practice Units
    December 15, 2021
  251. New Form 5471, Schedule J Video
    December 3, 2021
  252. 2022 Inflation Adjustments for Individuals in the International Tax Arena
    November 16, 2021
  253. 2021 3rd Quarter Published Expatriates
    November 12, 2021
  254. Two New IRS Practice Units - NRA employee expenses & Form 1040NR for RGS
    October 31, 2021
  255. Capitalization Trivia
    September 17, 2021
  256. 14 New Charts Published
    September 10, 2021
  257. New IRS Practice Unit - FTC (Business) General Principles
    September 2, 2021
  258. 2 New IRS Practice Units
    August 26, 2021
  259. Two New Heat Maps – AGI by State & Number of Dependents by State
    August 19, 2021
  260. Famous Tax Quotes - Taxes Are What We Pay For Civilized Society
    August 14, 2021
  261. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud
    August 4, 2021
  262. New IRS Practice Unit: Overview of IRC 987 and Branch Operations in a Foreign Currency
    August 4, 2021
  263. 2021 2nd Quarter Published Expatriates
    July 28, 2021
  264. IRS Data By Zip Code (Using Python and Flask)
    July 20, 2021
  265. 3 New IRS Practice Units
    July 9, 2021
  266. New IRS Practice Unit: Concepts of GILTI
    June 18, 2021
  267. 13 New Charts Published
    June 15, 2021
  268. 130 New Tax Charts – LOB Active Trade or Business Test – Derived In Connection With
    June 8, 2021
  269. New IRS Practice Unit: Allocation and Apportionment of Deductions
    May 21, 2021
  270. Famous Tax Quotes - A Detour to Crazy Town
    May 17, 2021
  271. 2021 1st Quarter Published Expatriates
    April 28, 2021
  272. Famous Tax Quotes - Two-Way Street: Downhill for the IRS & Uphill for the Taxpayer
    April 27, 2021
  273. New IRS Practice Units - FTC Carryback and Carryover & Liquidating Distributions of a Partner"s Interest in a Partnership
    April 12, 2021
  274. US Treaty Limitation on Benefits Status Map
    April 9, 2021
  275. AM 2021-002 – Relevance & Check-the-Box Elections
    April 3, 2021
  276. Flow-Thru Symbols: An Up-Side-Down "Funnel" Theme
    April 1, 2021
  277. Multiple new situational charts published
    April 1, 2021
  278. New IRS Practice Unit: 965 Transition Tax
    March 24, 2021
  279. Section 911 Housing Cost Amounts Updated for 2021
    March 2, 2021
  280. Famous Tax Quotes - Death May Escape the Woes of Life . . .
    February 20, 2021
  281. 2020 Sets New Record For Published Expatriates
    February 3, 2021
  282. A Brief History of U.S. Tax Expatriation Rules
    January 15, 2021
  283. U.K. Pension Lump-Sum Distributions
    November 8, 2020
  284. 7 New Tax Charts Published
    November 6, 2020
  285. 2021 Inflation Adjustments for Individuals in the International Tax Arena
    November 6, 2020
  286. IRS Delinquent International Information Return Submission Procedures Have Been Updated
    November 6, 2020
  287. Famous Tax Quotes - Memory Dulled by a Penitentiary Term Served
    November 3, 2020
  288. 2020 Third Quarter Published Expatriates – 2020 Is Already the Highest Year Ever
    October 28, 2020
  289. Famous Tax Quotes - Fictional Corporate Camouflage
    October 25, 2020
  290. 88% of Expatriates Have a Net Worth of Less than $2 Million
    October 18, 2020
  291. FBAR Reporting For Indirectly Owned Foreign Bank Accounts
    September 14, 2020
  292. A Tax Attorney Uses Python
    September 1, 2020
  293. New IRS Practice Unit: Foreign Earned Income
    August 27, 2020
  294. 2020 Second Quarter Published Expatriates – Second Highest Quarterly Number Ever
    August 13, 2020
  295. U.S. Partnerships Owning CFCs
    August 4, 2020
  296. Famous Tax Quotes - No Rational Person . . .
    July 29, 2020
  297. Famous Tax Quotes - Backdating of Documents
    July 28, 2020
  298. New IRS Practice Units: Reasonable Cause and Good Faith & FTC Limitation
    July 18, 2020
  299. Average Price of U.S. Real Estate Sold -- By Country
    July 3, 2020
  300. Famous Tax Quotes - Born in Generosity; Debauched in Avarice
    June 30, 2020
  301. 5 New Tax Charts Published
    June 17, 2020
  302. Free Flowchart - Section 894(c): Hybrid & Reverse Hybrid Entities
    June 9, 2020
  303. New IRS Practice Unit: Flow-Through Entities Effects on FTC
    June 4, 2020
  304. Two New (& One Updated) IRS Practice Units
    May 9, 2020
  305. 2020 First Quarter Published Expatriates –Highest Quarterly Number Ever
    May 7, 2020
  306. Three New IRS Practice Units
    April 29, 2020
  307. New IRS Practice Unit On The Statute Of Limitations
    April 11, 2020
  308. New IRS Practice Unit for "Adjustments for Overwithholding on Form 1042"
    April 8, 2020
  309. Rev. Proc. 2020-17 - Exemption From Filing Forms 3520 and 3520-A for Applicable Tax-Favored Foreign Trusts
    March 3, 2020
  310. Section 911 Housing Cost Amounts Updated for 2020
    February 25, 2020
  311. 11 New Tax Charts
    February 15, 2020
  312. 2019 Published Expatriates - Lowest Level in Six Years
    February 10, 2020
  313. New IRS Practice Unit – FDAP Statistical Sampling in the Audit of a U.S. Withholding Agent
    January 23, 2020
  314. Video - Downward Attribution Form 5471
    January 9, 2020
  315. Form 8993 With Graphic of Formulas
    December 26, 2019
  316. Famous Tax Quotes - Perhaps Congress Just Stubbed Its Toe
    December 17, 2019
  317. Video - Sec. 1446(f) Withholding on Sales of Partnerships Engaged in US Business
    December 12, 2019
  318. Famous Tax Quotes - Penalties For Hardheaded Persistence
    December 5, 2019
  319. Famous Tax Quotes - Like white asparagus or a blood orange
    December 3, 2019
  320. 2020 Inflation Adjustments for Individuals in the International Tax Arena
    November 18, 2019
  321. 2019 3rd Quarter Published Expatriates - Lowest Since 4th Quarter 2012
    November 8, 2019
  322. Famous Tax Quotes - The Regulations Barely Rocked The Statutory Boat
    October 24, 2019
  323. 8 New Charts Of Examples Regarding Classification of Cloud Transactions & Computer Programs
    September 26, 2019
  324. 2019 2nd Quarter Published Expatriates
    August 14, 2019
  325. Famous Tax Quotes - Forming HoldCo To Acquire Target Is Not Unusual
    August 7, 2019
  326. Famous Tax Quotes - A taxpayer"s own documents
    August 4, 2019
  327. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud
    June 5, 2019
  328. 2019 1st Quarter Published Expatriates - 1,019 Names
    May 10, 2019
  329. Section 911 Housing Cost Amounts Updated for 2019
    April 17, 2019
  330. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2018)
    April 17, 2019
  331. New IRS Practice Units published in March
    March 18, 2019
  332. 2018 4th Quarter Published Expatriates - A total of 685
    March 12, 2019
  333. GILTI Deduction Allowed With 962 Election (Proposed Regulations)
    March 5, 2019
  334. Eaton Corp. v. Commr., 152 T.C. No. 2 (2019)
    March 1, 2019
  335. New IRS Practice Unit: Creation of a Permanent Establishment (PE) through the Activities of a Dependent Agent in the United States
    January 31, 2019
  336. Rental of Real Estate to Yourself
    January 23, 2019
  337. Form 5472 Failure to File Penalty Increased to $25,000
    January 14, 2019
  338. The "Certification" on Form W-8BEN For Royalties
    January 7, 2019
  339. The "Certification" on Form W-8BEN For Interest
    December 31, 2018
  340. The "Certification" on Form W-8BEN For Dividends
    December 24, 2018
  341. The "Certification" on Form W-8BEN For Services
    December 17, 2018
  342. 2019 Inflation Adjustments for Individuals in the International Tax Arena
    November 20, 2018
  343. 2018 Third Quarter Published Expatriates – A Total of 1,107
    November 16, 2018
  344. New & Updated Draft International Forms
    October 19, 2018
  345. Video - GILTI for a CFC With & Without Debt
    October 19, 2018
  346. 12 New Tax Charts
    October 18, 2018
  347. Famous Tax Quotes - New Batboy Changing the Outcome of the World Series
    October 4, 2018
  348. Famous Tax Quotes - That"s How The Cookie Crumbles
    September 22, 2018
  349. Video – GILTI in a Minute
    September 17, 2018
  350. GILTI Regulations Preamble: Is a 100 Word Sentence Too Long?
    September 13, 2018
  351. 13 Charts of Code §958 Regulation Examples
    August 28, 2018
  352. 8 Charts of Sec. 965 Transition Tax Regulation Examples
    August 9, 2018
  353. 2018 Second Quarter Published Expatriates – A Total of 1,090
    July 31, 2018
  354. IRS 2015 Statistics on Form 8805 (Inbound Partnership Investing)
    June 29, 2018
  355. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud
    June 28, 2018
  356. 8 New Tax Charts
    June 28, 2018
  357. Famous Tax Quotes - IRS To Enforce Tax Laws; Not To Maximize Tax Receipts
    May 22, 2018
  358. 2018 First Quarter Published Expatriates – A Total of 1,099
    May 7, 2018
  359. IRS Publication on New Section 965 Transition Tax
    April 14, 2018
  360. Famous Tax Quotes - "One Big Wallet"
    April 14, 2018
  361. New Video – Attribution Rules for 965 Specified Foreign Corporations
    April 6, 2018
  362. Video on IRS FAQs on Section 965 Transition Tax Reporting
    March 20, 2018
  363. Video - Form 5471 Attribution from NRA Spouses
    March 9, 2018
  364. Qualified Electing Funds ("QEFs") Receiving Qualified Dividend Income
    March 1, 2018
  365. Code §965: Individuals Recognizing the Deemed Repatriation in 2017 vs. 2018
    February 14, 2018
  366. Update to Video: Global Intangible Low-taxed Income ("GILTI")
    February 10, 2018
  367. 2017 Fourth Quarter Published Expatriates – First Annual Decrease in Five Years
    February 8, 2018
  368. Andrew Mitchel Speaking on "GILTI" at IFA regional meeting
    February 2, 2018
  369. New Video: Form 2555 and the Foreign Earned Income Exclusion
    February 1, 2018
  370. TCJA Explanatory Video: Global Intangible Low-taxed Income ("GILTI")
    January 2, 2018
  371. Tax Cuts and Jobs Act Explanatory Video: Code §965 Deemed Repatriation from Foreign Corporations
    December 21, 2017
  372. New Flowchart – Form 5471 Filing Requirements
    November 13, 2017
  373. 2017 Third Quarter Published Expatriates – A Total of 1,376
    November 1, 2017
  374. 2018 Inflation Adjustments for Individuals in the International Tax Arena
    October 20, 2017
  375. 5 New Tax Charts
    October 20, 2017
  376. Famous Tax Quotes - Plodding Through A Tax Court Opinion
    September 24, 2017
  377. Famous Tax Quotes - Almost Indistinguishable Lines
    September 18, 2017
  378. Withdrawal of Prior Blog Post Regarding Australian Superannuation Funds
    September 14, 2017
  379. 5 New Tax Charts
    September 6, 2017
  380. Famous Tax Quotes - Anticlimactic Discoveries
    August 24, 2017
  381. 5 New Tax Charts
    August 10, 2017
  382. Belize IBC Selling Through Amazon FBA
    August 4, 2017
  383. 2017 Second Quarter Published Expatriates – Second Highest Ever
    August 2, 2017
  384. Tax Court Declines to Follow Rev. Rul. 91-32
    July 20, 2017
  385. Famous Tax Quotes - An Unsubstantiated Presumption
    July 6, 2017
  386. 5 New Tax Charts
    July 1, 2017
  387. Failures to Adjust for Inflation
    June 21, 2017
  388. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud
    June 11, 2017
  389. Famous Tax Quotes - Careful / Close / Extra / Heightened / Rigid / Special / Strict Scrutiny For Related Party Transactions
    June 9, 2017
  390. 5 New Tax Charts
    June 2, 2017
  391. 5 New Tax Charts
    May 12, 2017
  392. 2017 First Quarter Published Expatriates – A Total of 1,313
    May 9, 2017
  393. Famous Tax Quotes - Blind Guesses Are Not Good Faith Estimates
    March 30, 2017
  394. Famous Tax Quotes - Lower Court Overruling a Higher Court
    March 28, 2017
  395. Section 911 Housing Cost Amounts Updated for 2017
    March 24, 2017
  396. New Form 5472 Filing Requirements for Foreign-Owned U.S. Disregarded Entities ("FOUSDEs")
    March 6, 2017
  397. Being Engaged in U.S. Business Through Independent Agents
    February 27, 2017
  398. Famous Tax Quotes - Caligula & Taxes
    February 20, 2017
  399. 2016 Fourth Quarter Published Expatriates – New Annual Record
    February 8, 2017
  400. 15 New Tax Charts
    February 6, 2017
  401. Form 8886: Section 988 Losses >50k Can Be Reportable Transactions
    February 1, 2017
  402. Famous Tax Quotes - Congress Does Not Legislate in Logic Puzzles
    January 27, 2017
  403. Update to Form 8833 Flowchart (Treaty-Based Return Positions)
    January 27, 2017
  404. Free Flowchart – Reg 301.7701-7: Trusts -- Domestic and Foreign
    January 26, 2017
  405. Free Flowchart – Reg 301.6114-1 Disclosure of Treaty-Based Return Positions (Form 8833)
    January 23, 2017
  406. Increases in Private Letter Ruling Fees for 2017
    January 12, 2017
  407. PFIC Mark-to-Market Election Charts & Videos
    January 10, 2017
  408. The "Sailing Permit"
    December 28, 2016
  409. Final Code §987 Regulations!!
    December 26, 2016
  410. 23 New Charts - Code §956 Regulation Examples from T.D. 9792
    December 15, 2016
  411. Tax Return Preparation Automation
    December 2, 2016
  412. New Videos November 2016
    November 30, 2016
  413. 11 New Charts of Foreign Trust Distributions Through Intermediaries
    November 17, 2016
  414. 2016 Third Quarter Published Expatriates – Second Highest Ever
    November 9, 2016
  415. New Videos - October 2016
    October 31, 2016
  416. 2017 Inflation Adjustments for Individuals in the International Tax Arena
    October 27, 2016
  417. Over 50 New Situational Charts – Code §7874 Regulation Examples
    October 22, 2016
  418. Famous Tax Quotes - Source of Income When Business Is Begun In One Country And Ended In Another
    October 19, 2016
  419. New Videos - September 2016
    September 30, 2016
  420. New Videos - August 2016
    September 13, 2016
  421. Famous Tax Quotes - Clapping With One Hand
    August 26, 2016
  422. Free Flowchart – Reg. 1.937-1 – Bona Fide Residency in a U.S. Possession
    August 25, 2016
  423. Famous Tax Quotes - King Minos" Labyrinth
    August 3, 2016
  424. New Videos - July 2016
    July 29, 2016
  425. 2016 Second Quarter Published Expatriates
    July 28, 2016
  426. Substantiation of Deductions to Foreign Contractors
    July 22, 2016
  427. New Videos - June 2016
    June 30, 2016
  428. Free Flowchart - Form 5472 Filing Requirements (Code §§6038A and 6038C)
    June 7, 2016
  429. New Videos - May 2016
    May 31, 2016
  430. Famous Tax Quotes - "Tax Language"
    May 19, 2016
  431. Tax Treaty Limitation on Benefits ("LOB") & Form W8-BEN-E
    May 10, 2016
  432. Over 1,000 Published Expatriates in 2016 Q1 - The New Normal
    May 4, 2016
  433. New Videos - April 2016
    April 29, 2016
  434. Encouraging Foreign Investment - A Distorted U.S. Tax Policy
    April 3, 2016
  435. New Videos - March 2016
    March 31, 2016
  436. Section 911 Housing Cost Amounts Updated for 2016
    March 22, 2016
  437. Rev. Rul. 2016-8: Tax Aspects of the Cuban Thaw
    March 10, 2016
  438. New Videos - February 2016
    March 1, 2016
  439. Charts of Examples in Rev. Proc. 91-55: Form 5472 & Direct and Ultimate Indirect 25% Shareholders
    February 22, 2016
  440. New Expatriate Record for 2015 – Nearly 4,300 Expatriations
    February 5, 2016
  441. Famous Tax Quotes - Where to Draw the Line
    January 29, 2016
  442. Sale of Stock of a CFC – Example of the Potential Benefit of Code §1248(b)
    January 26, 2016
  443. Rev. Rul. 56-613 Video (Failed B Reorg - Indirect Control)
    January 24, 2016
  444. Flowchart - Section 267(a)(2) & (3) Related Party Matching Rules
    December 22, 2015
  445. FAST Act Passport Revocation Provisions
    December 11, 2015
  446. The Escalation of Offshore Penalties Over the Last 20 Years
    November 2, 2015
  447. 2015 Third Quarter Published Expatriates – A Record High
    October 26, 2015
  448. 2016 Inflation Adjustments for Individuals in the International Tax Arena
    October 23, 2015
  449. FATCA Overview - Crawford v. U.S. Dep't of the Treasury
    October 17, 2015
  450. Famous Tax Quotes - The Basic Structure of the Internal Revenue Code
    October 5, 2015
  451. Is the IRS Missing Names From Its Quarterly Publication of Expatriates?
    September 16, 2015
  452. Chart of Rev. Rul. 84-125 - Accrual of Foreign Tax Credit on Contested Liability & 10 Year Limitations Period
    September 7, 2015
  453. Charts of 704(c) Traditional Method & Trad. Meth. With Curative Allocations
    September 5, 2015
  454. Charts of Examples in Code §6038A Regulations: Form 5472 Reporting Requirements
    August 25, 2015
  455. Flowchart - PFIC Mark-to-Market Elections
    August 20, 2015
  456. Recent Publications
    August 14, 2015
  457. New FBAR Due Date
    August 12, 2015
  458. 2015 - 2016 IRS Priority Guidance Plan - International Issues
    August 11, 2015
  459. 2015 Second Quarter Published Expatriates – Lowest in Years
    July 30, 2015
  460. Video: U.S. Taxation of Foreign Vacation Homes Held Thru Entities
    June 29, 2015
  461. Application of PFIC Look-Through Rules to Foreign Corporation with U.S. Subsidiaries
    June 18, 2015
  462. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud
    June 9, 2015
  463. When an Active NFFE Can Be a Passive NFFE
    June 3, 2015
  464. Charts of Rev. Rul. 2015-09 & Rev. Rul. 2015-10
    May 11, 2015
  465. The Exodus Continues (2015 1st Quarter Published Expatriates)
    May 7, 2015
  466. Recognition of Losses on Dispositions of PFICs
    April 14, 2015
  467. Famous Tax Quotes - Muddled Tax Return Reporting
    April 2, 2015
  468. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2014)
    March 27, 2015
  469. JCT Excellent Summary of U.S. Cross-Border Tax Rules
    March 18, 2015
  470. 2014 - More Expatriations Than Ever
    February 10, 2015
  471. New Private Letter Ruling Fees
    February 5, 2015
  472. Charts of Examples in Notice 2014-52
    February 5, 2015
  473. A Reminder for Green Card Holders Living Outside the U.S.
    January 3, 2015
  474. Famous Tax Quotes - Residence - As Many Colors As Joseph's Coat
    January 1, 2015
  475. McLaulin – Failed Spin-Off (Situational Chart)
    December 29, 2014
  476. IRS International Practice Units
    December 23, 2014
  477. Video: Tax as a Percentage of GDP: 1965 to 2013
    December 17, 2014
  478. Famous Tax Quotes - A Rose is a Rose is a . . .
    December 13, 2014
  479. Chart of PLR With Outbound 332 Liquidation
    December 7, 2014
  480. Why U.S. Companies Invert Video
    December 3, 2014
  481. International PLRs of Note for the 46th and 47th week of 2014
    December 2, 2014
  482. Willful vs. Non-Willful FBAR Violations
    November 22, 2014
  483. IRS Documents Released Under Freedom of Information Act
    November 20, 2014
  484. New Rules for Canadian RRSPs & RRIFs
    November 2, 2014
  485. 2015 Inflation Adjustments for Individuals in the International Tax Arena
    November 2, 2014
  486. 2014 Third Quarter Published Expatriates – Third Highest Ever
    October 24, 2014
  487. Famous Tax Quotes - Taxing Citizens by Reason of Citizenship
    October 3, 2014
  488. Famous Tax Quotes - "Maxims" & "Minims"
    September 28, 2014
  489. Payments to Foreign Contractor Entities: Form W-8BEN-E
    September 22, 2014
  490. International PLRs of Note for the 38th week of 2014
    September 22, 2014
  491. Famous Tax Quotes - "Laughable" Test - All Caps Spelling
    September 10, 2014
  492. International PLRs of Note for the 36th week of 2014
    September 5, 2014
  493. International PLRs of Note for the 34th week of 2014
    August 22, 2014
  494. Chart of PLR 201432002: No Inversion as a Result of an F Reorganization & an IPO
    August 19, 2014
  495. Famous Tax Quotes - From the Brow of Zeus
    August 15, 2014
  496. International PLRs of Note for the 32nd week of 2014
    August 14, 2014
  497. 2014 Second Quarter Published Expatriates
    August 6, 2014
  498. Charts of Examples in Notice 2014-44
    July 28, 2014
  499. Past IRS Memoranda on the Singapore Central Provident Fund
    July 4, 2014
  500. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud
    June 13, 2014
  501. Chart of CCA 201420017: Code §956: Funneling of Loan through One CFC Partner is Disregarded
    May 20, 2014
  502. 2014 First Quarter Published Expatriates - Second Highest Ever
    May 1, 2014
  503. Section 911 Housing Cost Amounts Updated for 2014
    April 15, 2014
  504. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2013)
    March 27, 2014
  505. Chart of PLR 201411006 - Combination of Two Consolidated Groups Owned by Foreign Parent
    March 18, 2014
  506. International PLRs for the 10th week of 2014
    March 13, 2014
  507. Chart of Central de Gas de Chihuahua
    February 22, 2014
  508. International PLRs for the 7th and 8th week of 2014
    February 22, 2014
  509. Famous Tax Quotes - Can"t Have Your Cake and Eat It Too
    February 22, 2014
  510. Famous Tax Quotes - Hiding the Pea
    February 20, 2014
  511. Statute of Limitations for Foreign-Related Items
    February 18, 2014
  512. Famous Tax Quotes - Expatriation is a Serious Act
    February 16, 2014
  513. Charts of Examples in §1361 Regulations: Termination of QSub Elections
    February 14, 2014
  514. Quarterly List of Expatriates: Source of Data
    February 12, 2014
  515. 2013 Expatriations Increase by 221%
    February 6, 2014
  516. FBAR Video
    February 5, 2014
  517. International PLRs for the 5th week of 2014
    February 5, 2014
  518. International PLRs for the 4th week of 2014
    January 27, 2014
  519. Charts of Examples in §355 Regulations: Continuity of Interest
    January 24, 2014
  520. Charts of Examples in New PFIC Annual Filing Requirement Regulations (Form 8621)
    January 15, 2014
  521. International PLRs for the 2nd week of 2014
    January 12, 2014
  522. New Free Flowchart at Tax-Charts.com : Code §357 Assumption of Liabilities in Certain Exchanges
    January 9, 2014
  523. New Rules for PFIC Annual Filing (Form 8621)
    January 8, 2014
  524. International PLRs for the 1st week of 2014
    January 3, 2014
  525. International PLRs for the 52nd week of 2013
    December 31, 2013
  526. Free Simplified Section 351 Exchange Flowchart
    December 26, 2013
  527. International PLRs for the 51st week of 2013
    December 20, 2013
  528. Change to Weekly PLR Posts
    December 19, 2013
  529. Famous Tax Quotes - Morass of United States Tax Laws
    December 17, 2013
  530. International PLRs for the 50th week of 2013
    December 16, 2013
  531. Famous Tax Quotes - Earnings and Profits
    December 15, 2013
  532. Dover - Check-the-Box and Sale Video
    December 8, 2013
  533. Form 5471, Schedule J Video
    December 7, 2013
  534. International PLRs for the 49th week of 2013
    December 6, 2013
  535. New Resource Page: Monetary Penalties for Failure to File Common U.S. International Tax Forms
    December 4, 2013
  536. Chart of Rev. Rul. 66-79 - Deductibility of Contributions to "Foreign Feeder" Charity
    December 2, 2013
  537. Famous Tax Quotes - Precedent
    December 1, 2013
  538. International PLRs for the 48th week of 2013
    November 29, 2013
  539. Chart of Rev. Rul. 63-252 - Deductibility of Contributions to "Foreign Feeder" Charities
    November 27, 2013
  540. New Addition to the Blog: Resource Pages
    November 26, 2013
  541. International PLRs for the 47th week of 2013
    November 22, 2013
  542. International PLRs for the 46th week of 2013
    November 22, 2013
  543. Chart of Rev. Rul. 71-336 - Corporation as Conduit for Exchange of Stock a Taxable Transaction
    November 16, 2013
  544. International PLRs for the 45th week of 2013
    November 15, 2013
  545. Famous Tax Quotes - If Rube Goldberg Had Been a Tax Accountant
    November 15, 2013
  546. 2013 Third Quarter Published Expatriates
    November 13, 2013
  547. Chart of Rev. Rul. 67-192 - Section 367 Triggers Gain, but not Loss, in Outbound 351 Transaction
    November 12, 2013
  548. Chart of Chief Counsel Advice AM2013-006: §302 Redemption Reduces CFC's Pool of Foreign Income Taxes
    November 9, 2013
  549. International PLRs for the 44th week of 2013
    November 8, 2013
  550. Chart of Rev. Rul. 70-253 - Payment of Compensation to Partnership Employee Deductible by Partner under §162(a)
    November 5, 2013
  551. 2014 Inflation Adjustments for Individuals in the International Tax Arena
    November 4, 2013
  552. Chart of Rev. Rul. 66-365 - Solely for Voting Stock: Cash in Lieu of Fractional Shares
    November 4, 2013
  553. International PLRs for the 43rd week of 2013
    November 2, 2013
  554. International PLRs for the 42nd week of 2013
    November 2, 2013
  555. International PLRs for the 41st week of 2013
    October 31, 2013
  556. Chart of PLR 201340010 - Manufacturing Exception to FBCSI - Growing Activities can be Production Activities
    October 23, 2013
  557. International PLRs for the 40th week of 2013
    October 23, 2013
  558. Famous Tax Quotes - The Form of a Transaction Can Control Tax Consequences
    October 22, 2013
  559. Famous Tax Quotes - The IRM Holds No Legal Significance
    October 11, 2013
  560. Chart of PLR 201324005 - ADS Not Required for Possession Located Property Held Through Partnership
    October 2, 2013
  561. International PLRs for the 39th week of 2013
    September 27, 2013
  562. Chart of Rev. Rul. 90-76 - Foreign Corporations: Liquidating Distributions of USRPIs
    September 26, 2013
  563. Chart of PLR 201328003 - Deemed Distribution and Contribution with Circular Flow of Cash
    September 25, 2013
  564. International PLRs for the 38th week of 2013
    September 23, 2013
  565. Famous Tax Quotes - [Un]Comfortable Degree of Accuracy
    September 22, 2013
  566. New Attorney Announcement - Ryan E. Dunn
    September 20, 2013
  567. Situational Chart of Rev. Rul. 89-103 - Stapling of Interests Triggers Inbound "F" Reorganization
    September 17, 2013
  568. International PLRs for the 37th week of 2013
    September 13, 2013
  569. Situational Chart of Rev. Rul. 58-422 - Merger an "F" Reorg & Two 332 Liquidations
    September 13, 2013
  570. Situational Chart of Rev. Rul. 70-434 - Spin-Off & "B" Reorganization
    September 11, 2013
  571. Situational Charts of "F" Reorganizations of "S" Corporations
    September 9, 2013
  572. International PLRs for the 36th week of 2013
    September 6, 2013
  573. International PLRs for the 35th week of 2013
    September 5, 2013
  574. International PLRs of the 34th week of 2013
    September 5, 2013
  575. International PLRs of the 33rd week of 2013
    September 5, 2013
  576. International PLRs of the 32nd week of 2013
    September 5, 2013
  577. International PLRs of the 31st week of 2013
    September 5, 2013
  578. International PLRs of the 30th week of 2013
    September 5, 2013
  579. International PLRs of the 29th week of 2013
    September 5, 2013
  580. International PLRs of the 28th week of 2013
    September 5, 2013
  581. Famous Tax Quotes - Double Taxation Cannot Always Be Avoided
    August 30, 2013
  582. Situational Charts of Examples 8 and 9 of Treas. Reg. §1.1361-5(b)(3) - Terminations of Qsub Elections
    August 29, 2013
  583. International PLRs of the 27th week of 2013
    August 29, 2013
  584. International PLRs of the 26th week of 2013
    August 29, 2013
  585. International PLRs of the 25th week of 2013
    August 29, 2013
  586. International PLRs of the 24th week of 2013
    August 29, 2013
  587. Famous Tax Quotes - "Bureaucrats"
    August 28, 2013
  588. Famous Tax Quotes - Separate Entity Doctrine
    August 28, 2013
  589. International PLRs of the 23rd week of 2013
    August 26, 2013
  590. International PLRs of the 22nd week of 2013
    August 26, 2013
  591. International PLRs of the 21st week of 2013
    August 25, 2013
  592. International PLRs of the 20th week of 2013
    August 25, 2013
  593. International PLRs of the 19th week of 2013
    August 25, 2013
  594. Situational Chart of Rev. Rul. 78-401 - No Meaningful Reduction In The Shareholder's Proportionate Interest
    August 24, 2013
  595. International PLRs of the 18th week of 2013
    August 23, 2013
  596. International PLRs of the 17th week of 2013
    August 22, 2013
  597. International PLRs for the 16th week of 2013
    August 21, 2013
  598. International PLRs of the 15th week of 2013
    August 20, 2013
  599. International PLRs of the 14th week of 2013
    August 19, 2013
  600. International PLRs of the 13th week of 2013
    August 18, 2013
  601. International PLRs of the 12th week of 2013
    August 16, 2013
  602. IRS Rules Commission Income From Sales is Not FBCSI
    August 16, 2013
  603. Number of Expatriates Skyrockets Again (Second Quarter of 2013)
    August 9, 2013
  604. Tax Textbook Built Into Lamp
    July 21, 2013
  605. Mandatory Electronic Filing for FBARs Coming Soon
    June 13, 2013
  606. Daly v. Commr. - Abode Was in the U.S. - No Foreign Earned Income Exclusion Allowed
    June 12, 2013
  607. Fideicomisos/Mexican Land Trusts are Not Trusts (Finally)
    June 6, 2013
  608. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud
    June 1, 2013
  609. Inbound Overview Flowchart (for Sale)
    May 10, 2013
  610. Barnes Group - Structured Repatriation Was a Dividend
    May 10, 2013
  611. Q1 2013 - Highest Quarterly Number of Expatriates Ever (But . . . )
    May 8, 2013
  612. Section 911 Housing Cost Amounts Updated for 2013
    May 6, 2013
  613. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2012)
    April 12, 2013
  614. International PLRs & CCA of the 11th week of 2013
    March 22, 2013
  615. International PLRs of the 10th week of 2013
    March 21, 2013
  616. International PLRs of the 9th week of 2013
    March 4, 2013
  617. International PLRs of the 8th week of 2013
    February 26, 2013
  618. International PLR of the 7th week of 2013
    February 20, 2013
  619. 48% Decrease in Number of Expatriates for 2012
    February 14, 2013
  620. FATCA, NFFEs, and Draft W-8BEN-E - Unnecessary Complexity
    February 13, 2013
  621. International PLR of the 6th week of 2013
    February 11, 2013
  622. PLRs of the 5th week of 2013
    February 1, 2013
  623. International PLRs of the 4th week of 2013
    January 26, 2013
  624. Form 5471 Videos
    January 25, 2013
  625. International PLRs of the 3rd week of 2013
    January 19, 2013
  626. International PLRs for the 2nd week of 2013
    January 19, 2013
  627. Free Section 351 Exchange Flowchart
    January 18, 2013
  628. International PLRs of the 1st week of 2013
    January 4, 2013
  629. Senate Fiscal Cliff Bill Includes Retroactive Reinstatement of CFC Look-Thru Rule
    January 1, 2013
  630. International PLRs of the 52nd Week of 2012
    December 28, 2012
  631. International PLRs & CCA"s of the 51st week of 2012
    December 27, 2012
  632. International PLRs for the 50th week of 2012
    December 20, 2012
  633. Teaching International Tax at Quinnipiac University School of Law
    December 20, 2012
  634. International PLRs of the 49th week of 2012
    December 13, 2012
  635. Doctrine of Constructive Receipt
    December 13, 2012
  636. International PLRs of the 48th week of 2012
    November 30, 2012
  637. Summary of Form 8938 Filing Thresholds
    November 28, 2012
  638. International PLRs of the 47th week of 2012
    November 24, 2012
  639. International PLRs of the 46th week of 2012
    November 24, 2012
  640. International PLRs of the 45th week of 2012
    November 24, 2012
  641. IRS Rules that Mexican Fideicomiso is Not a Trust
    November 15, 2012
  642. International PLRs of the 44th week of 2012
    November 10, 2012
  643. Graphic on Inbound & Outbound
    November 7, 2012
  644. International PLRs of the 43rd Week of 2012
    November 5, 2012
  645. International PLRs of the 42nd week of 2012
    November 5, 2012
  646. International PLRs for the 41st week of 2012
    November 5, 2012
  647. International PLRs of the 38th, 39th & 40th weeks of 2012
    November 3, 2012
  648. Expatriates for the Third Quarter of 2012
    November 1, 2012
  649. USD School of Law - Procopio International Tax Institute
    October 26, 2012
  650. 2013 Inflation Adjustments for Individuals in the International Tax Arena
    October 23, 2012
  651. Repatriate Now? (Before the Bush Tax Cuts Expire)
    October 19, 2012
  652. Form 1099 for Payments to Foreign Contractors for Services?
    October 7, 2012
  653. Senate Committee Video Testimony - Offshore Profit Shifting
    October 1, 2012
  654. International PLRs of the 37th week of 2012
    September 15, 2012
  655. 8th Annual USD School of Law-Procopio International Tax Law Institute (Oct. 25th & 26th)
    September 10, 2012
  656. International PLRs of the 36th week of 2012
    September 8, 2012
  657. Famous Tax Quotes - Accounting Firm "Screw Up"
    September 5, 2012
  658. International PLR of the 35th week of 2012
    September 4, 2012
  659. Partnership Definition
    September 4, 2012
  660. Gratuitous Links to Local Visiting Nurses Association
    September 2, 2012
  661. Canada & U.S. to Apply the Authorized OECD Approach ("AOA") for Attribution of Business Profits
    September 2, 2012
  662. Belgian Municipal and Conurbation Income Taxes are Covered by the Treaty
    August 31, 2012
  663. International PLRs of the 34th week of 2012
    August 25, 2012
  664. International PLR of the 33rd week of 2012
    August 25, 2012
  665. International PLRs of the 32nd week of 2012
    August 25, 2012
  666. International PLRs & CCA of the 31st week of 2012
    August 24, 2012
  667. International PLRs of the 30th week of 2012
    August 24, 2012
  668. 189 Published Expatriates for Q2 of 2012
    August 2, 2012
  669. Joint FATCA Implementation Statements
    July 21, 2012
  670. International PLRs of the 29th week of 2012
    July 21, 2012
  671. International PLRs of the 28th week of 2012
    July 21, 2012
  672. International PLRs of the 26th week of 2012
    July 21, 2012
  673. International PLR of the 25th week of 2012
    July 21, 2012
  674. International PLRs of the 24th week of 2012
    June 16, 2012
  675. International PLRs of the 23rd week of 2012
    June 12, 2012
  676. International PLRs of the 22nd week of 2012
    June 12, 2012
  677. International PLR of the 21st week of 2012
    June 11, 2012
  678. International PLRs of the 20th week of 2012
    June 11, 2012
  679. Links to Expatriate Lists
    June 8, 2012
  680. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud
    June 2, 2012
  681. Update on 1997 Expatriation Data
    June 1, 2012
  682. Example of a Mini-Eduardo Saverin
    May 18, 2012
  683. Book Review: Transfer Pricing Answer Book 2012
    May 15, 2012
  684. International PLRs of the 19th week of 2012
    May 14, 2012
  685. All Cash D Reorganization Video - Example 16, Loss of Basis
    May 9, 2012
  686. All Cash D Reorganization Video
    May 2, 2012
  687. 460 Published Expatriates for Q1 of 2012
    April 29, 2012
  688. International PLRs of the 15th and 16th Weeks of 2012
    April 23, 2012
  689. Spin-Off to Foreign Parent Video
    April 21, 2012
  690. Aiken Industries Video
    April 17, 2012
  691. Brazilian tax package
    April 11, 2012
  692. International PLRs of the 14th week of 2012
    April 10, 2012
  693. International PLRs of the 13th week of 2012
    April 1, 2012
  694. International PLRs of the 12th week of 2012
    March 29, 2012
  695. B Reorganization Video
    March 24, 2012
  696. 1997 Had More U.S. Expatriations Than 2011
    March 19, 2012
  697. International PLRs of the 10th week of 2012
    March 16, 2012
  698. Attorney-Client Privilege Flowchart
    March 15, 2012
  699. International PLRs / CCAs of the 8th week of 2012
    March 2, 2012
  700. 10 Free New Tax Charts (Feburary 2012)
    March 2, 2012
  701. Section 911 Housing Cost Amounts Updated for 2012
    February 14, 2012
  702. International PLRs / CCAs of the 6th week of 2012
    February 12, 2012
  703. Famous Tax Quotes - Same Boat But Another Ocean
    February 5, 2012
  704. International PLRs / CCAs of the 5th week of 2012
    February 3, 2012
  705. Number of Expatriates for 2011
    February 2, 2012
  706. International PLRs / CCAs of the 4th week of 2012
    January 30, 2012
  707. International Aspects of Mitt Romney"s 2010 Tax Return
    January 27, 2012
  708. International PLRs of the 3rd week of 2012
    January 26, 2012
  709. Uncompensated Use of Foreign Trust Property
    January 25, 2012
  710. Income Accruing in Foreign Retirement Plans
    January 22, 2012
  711. New FBAR (Again) - Email Your Questions
    January 20, 2012
  712. International PLRs of the 2nd week of 2012
    January 20, 2012
  713. International PLRs of the 1st week of 2012
    January 6, 2012
  714. International PLRs of the 52nd Week of 2011
    December 31, 2011
  715. International PLRs of the 51st Week of 2011
    December 23, 2011
  716. This Post Has Been Updated
    December 23, 2011
  717. International PLRs of the 50th Week of 2011
    December 20, 2011
  718. Code §951 Inclusions Are Not Qualified Dividend Income
    December 17, 2011
  719. International PLRs of the 49th Week of 2011
    December 12, 2011
  720. Loan With "Kicker" is a USRPI
    December 8, 2011
  721. International PLRs of the 47th Week of 2011
    November 26, 2011
  722. International PLRs of the 46th Week of 2011
    November 18, 2011
  723. Subpart F Income
    November 14, 2011
  724. International PLRs of the 43rd Week of 2011
    November 11, 2011
  725. International PLRs of the week
    October 25, 2011
  726. 2012 Inflation Adjustments for Individuals in the International Tax Arena
    October 24, 2011
  727. New Brunswick Premier Caught in U.S. Tax Net
    October 3, 2011
  728. Goosen v. Commr. - Golfer Endorsement Fees
    August 23, 2011
  729. Notice 2011-64: Countries Qualifying for Reduced Dividend Tax Rates
    August 18, 2011
  730. Q2 of 2011 Had the Second Highest Number of "Published Expatriates"
    August 17, 2011
  731. U.K. Remittance Basis Charge ("RBC") is a Creditable Tax
    August 15, 2011
  732. Dagres - Ordinary Loss for Bad Debt of Private Equity Fund Manager
    August 12, 2011
  733. Double Taxation on Services
    July 26, 2011
  734. The "Repatriation IRA" [To Stimulate the Economy]
    July 7, 2011
  735. Is the Limitation On Benefits Provision in the Proposed Hungary Treaty Too Complex?
    July 7, 2011
  736. Free Section 736 Flowchart
    July 6, 2011
  737. YouTube Video on Busted Section 351 Exchanges
    June 29, 2011
  738. Flowchart of LOB Article of Chile-U.S. Income Tax Treaty
    June 27, 2011
  739. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud
    June 24, 2011
  740. Famous Tax Quotes - Transactions Between Related Parties Merit Extra Scrutiny
    June 23, 2011
  741. IRS Delays Annual Reporting for Foreign Financial Assets and P.F.I.C.s
    June 21, 2011
  742. This Post Has Been Updated
    June 17, 2011
  743. Additional Extension for Pre-2010 Signature Authority Only FBARs
    June 16, 2011
  744. Two New Flowcharts on Tax-Charts.com
    June 13, 2011
  745. U.S. Citizens Continue to Renounce
    June 10, 2011
  746. 10 Free New Tax Charts (June 2011)
    June 10, 2011
  747. Offshore Structure to Hold Iraqi Dinars?
    May 23, 2011
  748. Flowchart of Rev. Proc. 93-27
    May 12, 2011
  749. Doctrine of Cloth[e]ing
    May 2, 2011
  750. Should "goodwill" be one word or two words?
    March 31, 2011
  751. IRS Reporting of Bank Interest Paid to NRAs
    March 29, 2011
  752. Famous Tax Quotes - Valuation Is Not an Exact Science
    March 22, 2011
  753. NPR Podcast on Double Irish Structure
    March 18, 2011
  754. Famous Tax Quotes - Very definitely . . . probably
    March 17, 2011
  755. Famous Tax Quotes - Congress Can "label a thing income and tax it"
    March 9, 2011
  756. Number of Expatriates More Than Doubles
    March 4, 2011
  757. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2010)
    February 28, 2011
  758. 30% Tax for Interest Paid on Foreign Margin Account of U.S. Resident
    February 23, 2011
  759. Famous Tax Quotes - Seduced by a Siren Song of Symmetry
    February 18, 2011
  760. CCA 201106007 - Investments in U.S. Property - Intangibles
    February 14, 2011
  761. Famous Tax Quotes - Drawing Lines
    February 10, 2011
  762. PLR 201105011 Allows Re-Election of Revoked Code §911 Foreign Earned Income Exclusion
    February 6, 2011
  763. Section 911 Housing Cost Amounts Updated for 2011
    February 2, 2011
  764. 10 Free New Tax Charts (Jan. 2011)
    January 20, 2011
  765. Terminology for Hybrid Entities & Hybrid Instruments
    January 19, 2011
  766. Famous Tax Quotes - Too Good To Be True . . .
    December 28, 2010
  767. Famous Tax Quotes - A "Hat Problem"
    December 27, 2010
  768. Google Ngrams for Selected Tax Terms
    December 21, 2010
  769. Code § 954(c)(6) C.F.C. Look-Thru Rule Retroactive Reinstatement
    December 17, 2010
  770. 10 Free New Tax Charts
    December 7, 2010
  771. Famous Tax Quote #37 - Is Fido a dog?
    December 7, 2010
  772. Famous Tax Quote #36 - Differences in Degree vs. Differences in Kind
    November 11, 2010
  773. International Financial Scams - Overseas Investments, Lotteries, Inheritances, Gifts, etc.
    November 2, 2010
  774. Famous Tax Quote #35 - Foresight and Planning
    October 31, 2010
  775. 2011 Inflation Adjustments for Individuals in the International Tax Arena
    October 28, 2010
  776. Two New Flowcharts
    October 27, 2010
  777. Google"s Use of Double Irish Structure
    October 21, 2010
  778. Expatriations Continue Upward Trend
    October 21, 2010
  779. OECD Commentary on Electronic Commerce for Permanent Establishments
    October 18, 2010
  780. Free Flowchart of Rev. Proc. 2009-41
    October 12, 2010
  781. Famous Tax Quote #34 - A Word is Not a Crystal
    September 24, 2010
  782. Famous Tax Quote #33 - A melody is more than the notes
    September 20, 2010
  783. Software Classification Flowchart
    September 16, 2010
  784. Famous Tax Quote #32 - Change in the tax laws is a way of life
    September 3, 2010
  785. Tax Crimes, Tax Fraud, Tax Schemes
    August 30, 2010
  786. Famous Tax Quote #31 - If Pigs Had Wings, They Could Fly
    August 25, 2010
  787. Famous Tax Quote #30 - A Judicial Moon
    August 17, 2010
  788. New Section 956 Foreign Tax Credit Blending Rule
    August 13, 2010
  789. Should Congress Force An Accounting Rule Change?
    July 28, 2010
  790. Hybrid Entities and Reverse Hybrid Entities
    July 27, 2010
  791. Famous Tax Quote #29 - Taxing Corporate Distributions
    July 4, 2010
  792. Famous Tax Quote #28 - Purpose of Subpart F Income
    June 27, 2010
  793. What is a "check-the-box" election?
    June 25, 2010
  794. Famous Tax Quote #27 - All of life is a risk
    June 13, 2010
  795. Famous Tax Quote #26 - Business Purpose / Economic Substance
    June 6, 2010
  796. U.S. Model Treaty: Limitation on Benefits Flowchart
    June 3, 2010
  797. Famous Tax Quote #25 - Broker vs. Dealer
    May 30, 2010
  798. Covered Expatriate Flowchart
    May 27, 2010
  799. Subpart F Income Partnership Blocker Update
    May 25, 2010
  800. Famous Tax Quote #24 - Name for a Partnership With No Business Purpose
    May 23, 2010
  801. Double Irish Structure - Time for a New Tax Penalty?
    May 20, 2010
  802. Pensions Under the Belgium-U.S. Income Tax Treaty
    May 18, 2010
  803. Famous Tax Quote #23 - Motives Immaterial in a Code § 368(a)(1)(D) Reorganization
    May 16, 2010
  804. Canada-U.S. Treaty - Guidance on Deemed Sale/Purchase Election
    May 13, 2010
  805. Famous Tax Quote #22 - Redemption as a Step in a Reorganization
    May 11, 2010
  806. Foreign "EZ Pass" --- A Foreign Financial Account?
    May 7, 2010
  807. Sourcing By Analogy
    May 2, 2010
  808. Famous Tax Quote #21 - The Words Dance Before My Eyes
    May 2, 2010
  809. New PFIC Annual Reporting Rules
    April 7, 2010
  810. Beware Gifts to Non-Citizen Spouses
    April 2, 2010
  811. New Foreign Asset Disclosure Rules Enacted
    March 20, 2010
  812. A Circumvention of the Spirit of the Law?
    March 19, 2010
  813. U.S. Expatriations Skyrocket
    March 1, 2010
  814. Guarantee Fees Analogized as Services
    February 18, 2010
  815. IRS Rulings on Manufacturing Branch Rule
    February 11, 2010
  816. Cash D Reorganizations & the Meaningless Gesture Doctrine
    February 11, 2010
  817. Famous Tax Quote #20 - Tax Reduction Is Not Evil
    February 10, 2010
  818. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2009)
    February 5, 2010
  819. Famous Tax Quote #19 - How many legs does a dog have?
    February 3, 2010
  820. 97th Anniversary of the 16th Amendment
    February 3, 2010
  821. Offshore Bearer Bonds
    January 8, 2010
  822. Alice in Wonderland
    December 31, 2009
  823. Sourcing Rules for Telecoms" International Communications Income
    December 20, 2009
  824. Famous Tax Quote #18 - "Dummy" Corporations
    December 16, 2009
  825. Famous Tax Quote #17 - Taxation depends on actual events
    December 8, 2009
  826. Famous Tax Quote #16 - Taxation is Not Cuneiform.
    December 5, 2009
  827. Famous Tax Quote #15 - Simple Expedient of Drawing Up Papers
    December 2, 2009
  828. Liechtenstein Anstalts & Stiftungs
    November 24, 2009
  829. Expatriations on the Rise Again
    November 19, 2009
  830. Famous Tax Quote #14 - Mere Formalisms
    November 16, 2009
  831. Famous Tax Quote #13 - Anticipatory Assignment
    November 13, 2009
  832. Famous Tax Quote #12 - Income Is Taxed to The Earner
    November 4, 2009
  833. Overseas Inheritance Scam: Tax Certificate for Wire Transfer
    October 14, 2009
  834. FBAR Reporting for Foreign Mutual Funds
    September 18, 2009
  835. Three Manufacturing Tests Under Code § 954(d) & the Manufacturing Branch Rules
    September 11, 2009
  836. Green Card Holders Living Outside the U.S.
    September 10, 2009
  837. Schering-Plough Corp. v. U.S.
    September 5, 2009
  838. Famous Tax Quote #11 - Exalting Form Over Substance
    September 4, 2009
  839. IRS Extends Due Date for Late Check-the-Box Elections
    September 3, 2009
  840. Famous Tax Quote #10 - Meaningless Gesture
    September 2, 2009
  841. Famous Tax Quote #9 - Origin of All Events Test
    August 28, 2009
  842. Widely Held vs. Closely Held
    August 26, 2009
  843. "Inbound" & "Outbound"
    August 24, 2009
  844. Free Code § 302 Redemption Flowchart
    August 19, 2009
  845. Famous Tax Quote #8 - Tax Rules Don't Necessarily Make Sense
    August 14, 2009
  846. Famous Tax Quote #7 - Contingent Liabilities
    August 10, 2009
  847. Tax Chart Shape & Color Conventions
    July 31, 2009
  848. Famous Tax Quote #6 - Presumption of Correctness
    July 30, 2009
  849. Foreign Deferral Matching Principle
    July 20, 2009
  850. Famous Tax Quotes #4 & #5 - No Patriotic Duty to Increase Taxes
    July 14, 2009
  851. Famous Tax Quote #3 - Deductions Legislative Grace
    July 10, 2009
  852. Famous Tax Quote #2 - What Actually Occurred
    July 5, 2009
  853. Famous Tax Quote #1 - Straight Path / Devious Path
    July 3, 2009
  854. Qualified Business Units (QBUs)
    June 30, 2009
  855. IRS Additional FAQs Regarding Filing of FBAR and other Cross-Border Tax Forms
    June 26, 2009
  856. UBS Client Pleads Guilty to Filing False Tax Return
    June 25, 2009
  857. Branch Rule Complexity Continued
    May 12, 2009
  858. Branch Rule Complexity
    May 12, 2009
  859. Deemed Permanent Establishment, But Not Carrying On Business
    May 1, 2009
  860. Offshore Asset Protection Misconceptions
    April 28, 2009
  861. IRS Finally Publishes 2008 Form 8804
    March 22, 2009
  862. Modifications to Section 367 in Outbound Section 304 Transactions
    February 27, 2009
  863. "Unrelated" Financial Institution Under U.S.-Australia Income Tax Treaty
    February 2, 2009
  864. Treaty Limits on Reduced Dividend Withholding Rates for U.S. Mutual Funds
    December 31, 2008
  865. Ireland - What"s Not to Like?
    December 2, 2008
  866. Foreign Bank Secrecy & Tax Evasion
    November 26, 2008
  867. Irish Times: "Obama could be bad for Ireland"
    October 27, 2008
  868. Treasury Department"s Billion Dollar Tax Bailout for Banks By Fiat
    October 1, 2008
  869. Poor Grammar in Drafting of CFC Statutes
    September 22, 2008
  870. Section 367 - Exceptions Upon Exceptions
    August 22, 2008
  871. IRS Shuts Down Another Repatriation Technique
    August 8, 2008
  872. New Tax Charts
    July 18, 2008
  873. 5 Charts of Non-U.S. Tax Cases
    July 10, 2008
  874. Chart of Killer Forward Triangular Merger
    July 7, 2008
  875. IRS to Scrutinize International Transactions of Smaller Companies
    July 6, 2008
  876. New Expatriation Rules for High Net Worth Individuals
    June 29, 2008
  877. Treasury Issues Regulations to Close Repatriation Loophole
    June 22, 2008
  878. U.S. "State" Tax Residency (Domicile)
    June 1, 2008
  879. Canadian Outbound Taxation
    May 25, 2008
  880. Treaty Shopping & Anti-Treaty Shopping
    May 18, 2008
  881. Bulgarian Aktsionerno Druzhestvo Added To Per Se Corporation List
    May 4, 2008
  882. Inheriting Foreign Real Estate Inside a Foreign Corporation
    April 6, 2008
  883. U.S. Competitiveness and Corporate Tax Rates
    March 30, 2008
  884. Electronic Arts Chart
    March 23, 2008
  885. The Foreign Base Company Sales Income "Manufacturing Exception"
    March 13, 2008
  886. Third Circuit Reverses Tax Court in Swallows Holdings
    February 25, 2008
  887. Foreign Vacation Homes & Rental Properties
    February 8, 2008
  888. Practitioner Cross-Border Activities Can be Costly
    February 6, 2008

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The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.


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