Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues

Links to Blog Posts

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