Links to All Blog Posts

1. In the Tax Court & at the IRS Last Month --- August 2026

   September 1, 2026
2. Bruyea & Christensen Reversed - No FTC for NIIT

   September 1, 2026
3. Enrolled Agents By Country and By State (August 2026)

   August 27, 2026
4. Tax Authorities Search

   August 25, 2026
5. In the Tax Court & at the IRS Last Month --- July 2026

   August 13, 2026
6. Expatriations Are on the Rise Again (2026 2nd Quarter Published Expatriates)

   July 22, 2026
7. Chart of PLR 202629003 (Late Relief for FIRPTA Withholding Certificate)

   July 20, 2026
8. Graph of Number of Disciplined Tax Professionals

   July 8, 2026
9. FIRPTA Withholding by the Buyer Is Generally Required

   July 3, 2026
10. In the Tax Court & at the IRS Last Month --- June 2026

    July 2, 2026
11. IRS Removes Delinquent FBAR Submission Procedures

    July 1, 2026
12. Filtered List of Overseas Tax Preparers

    June 25, 2026
13. In the Tax Court & at the IRS Last Month --- May 2026

    June 5, 2026
14. 57 U.S. Income Tax Treaties

    May 30, 2026
15. Tax Court Opinion Search

    May 27, 2026
16. IRS Treaty Table 3: List of Tax Treaties - Portugal Protocol

    May 6, 2026
17. Chart of PLR 202611004 (865(h)(2)(A) Election for Sale of Indian Stock)

    May 3, 2026
18. In the Tax Court & at the IRS Last Month --- April 2026

    May 2, 2026
19. 2026 1st Quarter Published Expatriates - Trending Up

    April 21, 2026
20. Section 911 Housing Cost Amounts Updated for 2026

    April 7, 2026
21. Section 987 Equity and Basis Pool Method Calculator

    April 7, 2026
22. In the Tax Court & at the IRS Last Month --- March 2026

    April 2, 2026
23. Chart of PLR 202613004 (865(h)(2)(A) Election)

    March 28, 2026
24. Number of Chief Counsel Advice Emails

    March 24, 2026
25. Update to Classification of Transactions Chart (Waterman Steamship, etc.)

    March 7, 2026
26. Chart of PLR 202607002 (Treaty Rate for BPT With U.S. LLC)

    March 4, 2026
27. Tax Court Corrects It's Budget Justification

    March 1, 2026
28. In the Tax Court & at the IRS Last Month --- February 2026

    March 1, 2026
29. Famous Tax Quotes - Fabricated Case Citations (AI Hallucinations)

    February 11, 2026
30. Tax Court Again Overstates Number of Opinions Issued

    February 10, 2026
31. Exchange Rates for 2025

    February 10, 2026
32. Court Listener - Citation Lookup for Tax-Related Opinions

    February 6, 2026
33. In the Tax Court & at the IRS Last Month --- January 2026

    February 3, 2026
34. 2025 4th Quarter Published Expatriates (2% Increase Year-Over-Year)

    January 22, 2026
35. PFIC Calculator (Sales & Distributions)

    January 20, 2026
36. Tax Court Number of Pages / Tokens Analysis

    January 8, 2026
37. The Case of C.M. and the Border Run (Poem, AI Assist Generated)

    January 7, 2026
38. IRS Table 3. List of Tax Treaties Has Been Updated

    January 7, 2026
39. Chart of PLR 202551006 (Outbound 351 of Built-In Loss Property)

    January 5, 2026
40. 2025 Stats - Tax Court Opinion Release Patterns

    January 1, 2026
41. 2025 Stats - Pro Se Opinions in the Tax Court

    January 1, 2026
42. 2025 Stats - Opinions Cited To By the Tax Court

    January 1, 2026
43. 2025 Stats - Code Sections Cited To By the Tax Court

    January 1, 2026
44. 2025 Stats - Tax Court Opinions By Year

    January 1, 2026
45. 2025 Stats - Tax Court Opinions By Judge

    January 1, 2026
46. 2025 Stats - Pages in the Internal Revenue Bulletin Decrease By 23%

    January 1, 2026
47. 2025 Stats - IRS Written Determinations Increase By 10%

    January 1, 2026
48. In the Tax Court & at the IRS Last Month --- December 2025

    January 1, 2026
49. 2026 PLR Fees For 9100 Relief Remain the Same

    December 26, 2025
50. Chart of Example in Notice 2025-77

    December 20, 2025
51. Effective Tax Rate Calculations for Check the Box Analysis

    December 17, 2025
52. Famous Tax Quotes - Tax Planning Is As American As Apple Pie

    December 13, 2025
53. Sourcing of Income Quiz

    December 10, 2025
54. Enrolled Agents In India Increase By Nearly 1,000

    December 7, 2025
55. In the Tax Court & at the IRS Last Month --- November 2025

    December 1, 2025
56. Corporate Tax Quiz

    November 22, 2025
57. 2025 3rd Quarter Published Expatriates - Higher Than Typical

    November 14, 2025
58. You Don't Usually See Cites to Wrong Code Sections in Tax Court Cases

    November 14, 2025
59. Famous Tax Quotes - Congressionally Induced Transactions

    November 13, 2025
60. In the Tax Court & at the IRS Last Month --- October 2025

    November 3, 2025
61. Attorneys Must Represent Estates Before the Court of Federal Claims (Sovereign Citizen)

    October 23, 2025
62. PTIN Names and Contact Info

    October 20, 2025
63. 2026 Inflation Adjustments for Individuals in the International Tax Arena

    October 12, 2025
64. In the Tax Court & at the IRS Last Month --- September 2025

    October 4, 2025
65. More IRS Treaty Documents

    October 3, 2025
66. Chart of 3M Company v. Commr. (IRS Loses)

    October 2, 2025
67. The "Saving Clause"

    September 25, 2025
68. Chart of AM 2025-002 (BPT Treaty Relief for Rev. Hybrid Entity With US Branch)

    September 21, 2025
69. Semantic Search - Thinking Out Loud

    September 19, 2025
70. In the Tax Court & at the IRS Last Month --- August 2025

    September 19, 2025
71. Times Are A-Changing - TaxProf Blog Is Ending

    September 16, 2025
72. IRS Treaty Documents Are Slowly Improving

    September 15, 2025
73. IRS Publishes Technical Explanations to 1971 Norway Treaty and 1980 Norway Protocol

    September 6, 2025
74. In the Tax Court & at the IRS Last Month --- July 2025

    August 13, 2025
75. Self-Employed Abroad

    August 7, 2025
76. 2025 2nd Quarter Published Expatriates

    July 30, 2025
77. Notes on the OBBB

    July 27, 2025
78. In the Tax Court & at the IRS Last Month --- June 2025

    July 1, 2025
79. Guide to Tax Court Docket Suffixes

    June 30, 2025
80. In the Tax Court & at the IRS Last Month --- May 2025

    June 17, 2025
81. Free Flowchart - Section 2040: Portion of Jointly Owned Property to Include in Gross Estate

    May 27, 2025
82. Hawaiian Philippine Added to Classification of Transactions Chart

    May 24, 2025
83. You Can"t Rely on a Tax Opinion When the Opinion Writer Says It Is Hogwash

    May 16, 2025
84. Elections Related to Foreign Taxes

    May 16, 2025
85. IRS Publishes Technical Explanation to 1974 Polish Treaty

    May 8, 2025
86. In the Tax Court & at the IRS Last Month --- April 2025

    May 7, 2025
87. Tax Court Again Overstates Number of Opinions Issued

    May 3, 2025
88. 2 New IRS Practice Units

    May 2, 2025
89. Famous Tax Quotes - A Multiplier of 54 and Fantastical Numbers

    May 1, 2025
90. 2025 1st Quarter Published Expatriates

    April 23, 2025
91. Famous Tax Quotes - Garden Variety Negligence

    April 19, 2025
92. 6 New IRS Practice Units

    April 17, 2025
93. Famous Tax Quotes - We Can't Just Guess

    April 11, 2025
94. In the Tax Court & at the IRS Last Month --- March 2025

    April 10, 2025
95. 3 New IRS Practice Units

    April 9, 2025
96. IRS Denies Indirect Foreign Tax Credits For Failure to Attach Code §962 Election Statement

    April 8, 2025
97. 2 New IRS Practice Units

    April 4, 2025
98. 5 New IRS Practice Units

    April 2, 2025
99. Number of Chief Counsel Advice Emails

    March 28, 2025
100. In the Tax Court & at the IRS Last Month --- February 2025

     March 26, 2025
101. 8 New IRS Practice Units

     March 25, 2025
102. Tax Court Summary Opinions - Average of 83 Percent of Pro Se Opinions

     March 12, 2025
103. Percentage of Pro Se Opinions in the Tax Court (2001 to 2024)

     March 10, 2025
104. Zip Codes Updated and Enhanced for 2022 Data

     March 4, 2025
105. Filtering of TaxProf Blog Posts

     February 12, 2025
106. Famous Tax Quotes - Nailing Jello to a Wall

     February 10, 2025
107. 2024 IRS Tax Forum PowerPoints

     February 6, 2025
108. In the Tax Court & at the IRS Last Month --- January 2025

     February 4, 2025
109. 2024 Expatriations Increase by 48%

     January 31, 2025
110. Three New FTC Practice Units

     January 30, 2025
111. IRS Tax Exempt Determination Letters Are Not Searchable (They Should Be)

     January 29, 2025
112. In the Tax Court & at the IRS Last Month --- December 2024

     January 28, 2025
113. There Are a Lot of Enrolled Agents in California (Heat Map)

     January 27, 2025
114. Number of Tax Court Opinions Issued By Active Status Judges in 2024

     January 12, 2025
115. Exchange Rates for 2024

     January 9, 2025
116. Supreme & Appellate Court Opinions Cited By the Tax Court in 2024

     January 1, 2025
117. 2025 PLR Fees For 9100 Relief Increase By 15%

     December 29, 2024
118. A Record Number of Pages Published in the Internal Revenue Bulletin for 2024

     December 28, 2024
119. AM 2024-005 - Source of Gain From Certain Dispositions of Stock

     December 21, 2024
120. Review of An IRS-Prepared Form 5471

     December 19, 2024
121. PLR 199914006 - An LLC With 2 Members Was A Disregarded Entity

     December 19, 2024
122. PLR 200923001 (now revoked) - Domestically Controlled REIT

     December 18, 2024
123. PLR 201451009 - Professional Corps Ruled Part Of Affiliated Group

     December 10, 2024
124. IRS Removes Inaccurate Version of the Swedish Treaty

     December 7, 2024
125. Video on Reporting Rules for UK SIPPs

     December 6, 2024
126. Newly Released Treaty Documents

     December 6, 2024
127. In the Tax Court & at the IRS Last Month --- November 2024

     December 4, 2024
128. Lawsky Practice Problems

     December 2, 2024
129. FICA and Self-Employment Tax For Salaries Paid By a Foreign DRE

     November 17, 2024
130. Rev. Rul. 84-79 - Shares Owned Through a Revocable Voting Trust

     November 16, 2024
131. Tax Court Overstates Number of Opinions Issued In Report to Congress (again)

     November 14, 2024
132. Rev. Rul. 77-467 - Redemption With Waiver of Family Attribution & Rental of Real Estate

     November 7, 2024
133. Beneficial Ownership Controls For Consolidated Returns (Miami National Bank)

     November 6, 2024
134. More on Classifying Transactions

     November 5, 2024
135. Famous Tax Quotes - Rococo Fugue & Baroque Fugue

     November 3, 2024
136. In the Tax Court & at the IRS Last Month --- October 2024

     November 2, 2024
137. 2024 3rd Quarter Published Expatriates - Highest In 4 Years

     October 28, 2024
138. Distribution of Own Debt As a Dividend (Kraft Foods)

     October 27, 2024
139. Famous Tax Quotes - Five "Any's" In One Sentence

     October 23, 2024
140. 2025 Inflation Adjustments for Individuals in the International Tax Arena

     October 22, 2024
141. Rev. Rul. 75-512 - Redemption Not Equivalent to a Dividend Under 302(b)(1)

     October 20, 2024
142. Rev. Rul. 70-469 - Nominal Ownership - Affiliated Group Definition

     October 19, 2024
143. Passive Income For Less Than 10% Limited Partner (Chart)

     October 13, 2024
144. In the Tax Court & at the IRS Last Month --- September 2024

     October 4, 2024
145. Rev. Rul. 76-19 - Canadian Corp With Employees In the U.S.

     October 1, 2024
146. CFC Overlap Rule to Avoid PFIC Classification (PLR 200943004 & Reg. 1.958-1(d))

     September 30, 2024
147. Famous Tax Quotes - A Slender Reed

     September 27, 2024
148. Captive Insurance Companies Can Have A Disastrous Tax Result (CCA 202422010)

     September 23, 2024
149. Enrolled Agents By Country (September 2024)

     September 21, 2024
150. "Principals" as Partners in a Partnership

     September 16, 2024
151. No 245A DRD for Dividends from a SFC to a CFC

     September 12, 2024
152. In the Tax Court & at the IRS Last Month --- August 2024

     September 1, 2024
153. Where Is the GILTI High-Tax Exception?

     August 30, 2024
154. In the Tax Court & at the IRS Last Month --- July 2024

     August 21, 2024
155. Update to Chart - Classification of Transactions

     August 15, 2024
156. 2024 2nd Quarter Published Expatriates

     July 31, 2024
157. New Resource Page - Certain High Thresholds

     July 25, 2024
158. Famous Tax Quotes - Does Not Pass the Smell Test

     July 16, 2024
159. In the Tax Court & at the IRS Last Month --- June 2024

     July 5, 2024
160. Famous Tax Quotes - Shoebox Method

     June 10, 2024
161. In the Tax Court & at the IRS Last Month --- May 2024

     June 2, 2024
162. Deciphering Tax Court Opinion Release Patterns

     May 30, 2024
163. Four New Charts

     May 26, 2024
164. In the Tax Court & at the IRS Last Month --- April 2024

     May 16, 2024
165. 2024 1st Quarter Published Expatriates

     May 1, 2024
166. Chart for the Tax Court Case of PICCIRC, LLC --- Disguised Sale & Partnership Shams

     April 23, 2024
167. Famous Tax Quotes - The Proof of the Pudding is in the Eating

     April 21, 2024
168. In the Tax Court & at the IRS Last Month --- March 2024

     April 1, 2024
169. Section 911 Housing Cost Amounts Updated for 2024

     March 21, 2024
170. In the Tax Court Last Month --- February 2024

     March 6, 2024
171. Enrolled Agents Per Million People By State

     March 3, 2024
172. Enrolled Agents By Country (September 2023)

     February 25, 2024
173. Famous Tax Quotes - A Conjurer"s Circle

     February 20, 2024
174. Famous Tax Quotes - Must Timely File Using The Best Information Available

     February 11, 2024
175. Famous Tax Quotes - Insurance Premiums Were Nonsense

     February 4, 2024
176. Tax Court Statistics - 2023

     January 27, 2024
177. 2023 4th Quarter Published Expatriates

     January 26, 2024
178. Exchange Rates for 2023

     January 9, 2024
179. Pages Published by the IRS in 2023 (in the Federal Register & in the IRB)

     January 8, 2024
180. IRS Written Determinations Increased By 4% In 2023

     January 2, 2024
181. 2024 PLR Fees For 9100 Relief Remain the Same

     December 30, 2023
182. Videos Published in 2023

     December 27, 2023
183. Situational Charts Published in 2023

     December 22, 2023
184. Famous Tax Quotes - A Bundle of Sticks

     December 17, 2023
185. Top 8 Appellate Court Cases Cited by the Tax Court

     December 11, 2023
186. Top 10 Supreme Court Cases Cited by the Tax Court

     December 4, 2023
187. New IRS Practice Unit - Taxation of Beneficiary of a Foreign Non-Grantor Trust

     December 1, 2023
188. Famous Tax Quotes - Tweedledum and Tweedledee

     November 19, 2023
189. Famous Tax Quotes - Congress Does Not Hide Elephants In Mouseholes

     November 18, 2023
190. Regular Expressions in the Tax World

     November 10, 2023
191. 2024 Inflation Adjustments for Individuals in the International Tax Arena

     November 9, 2023
192. 2023 3rd Quarter Published Expatriates

     October 27, 2023
193. Famous Tax Quotes - Hard To See Duress Without Any IRS Interaction

     October 15, 2023
194. Tax Court Judge Lauber Is a Rock Star

     September 20, 2023
195. New situational charts published today

     September 11, 2023
196. 2023 2nd Quarter Published Expatriates

     July 20, 2023
197. New IRS Practice Unit: Expatriation – Mark-to-Market Tax Regime

     July 13, 2023
198. New IRS Practice Unit - FTC - Categorization of Income and Taxes Into Proper Basket

     June 27, 2023
199. Zip Codes Updated for 2020 Data

     June 3, 2023
200. Famous Tax Quotes - Confusing the Terms "Petitioner" and "Respondent"

     May 19, 2023
201. Three New IRS Practice Units - 267(a)(3), 385, and 163(j) for CFCs

     May 18, 2023
202. Treaty Updates Page

     May 15, 2023
203. Famous Tax Quotes - Bargaining For Tax Benefits

     April 19, 2023
204. 2023 1st Quarter Published Expatriates

     April 18, 2023
205. Famous Tax Quotes - Tax Laws Should Be Intelligible

     April 4, 2023
206. The IRS Publishes Far Fewer PLRs Than It Used To

     March 31, 2023
207. 4,000 Tax Cases and Rulings

     March 27, 2023
208. 3 New Videos – PFIC With No QEF, Pedigreed QEF, & Unpedigreed QEF

     March 21, 2023
209. Famous Tax Quotes - The Most Honorable People I Have Ever Dealt With

     March 18, 2023
210. Section 911 Housing Cost Amounts Updated for 2023

     March 16, 2023
211. Famous Tax Quotes - Self-serving, Unreliable, Unverified, and Contradicted Testimony

     March 11, 2023
212. Musings on Structure Planning For Closely-Held Foreign Entities

     March 6, 2023
213. Famous Tax Quotes - "To tautologize, section 741 applies only where it applies"

     February 17, 2023
214. IRS Regulations Lowest in 24 Years

     February 13, 2023
215. Charts Created in 2022

     February 11, 2023
216. 2022 Published Expatriates Increases By 57%

     January 26, 2023
217. Exchange Rates for 2022

     January 25, 2023
218. A Tangled Web of Definitions

     January 4, 2023
219. ChatGPT – Fun, But Not Yet Serious for Legal Writing

     December 7, 2022
220. Property of Former US Residents: Owning Stock Through a Partnership

     December 2, 2022
221. Recent Regulation Packages Related To International Tax

     October 29, 2022
222. 2022 3rd Quarter Published Expatriates

     October 25, 2022
223. 2023 Inflation Adjustments for Individuals in the International Tax Arena

     October 20, 2022
224. New IRS Practice Unit – FBAR (FinCEN Form 114)

     October 19, 2022
225. How inaccurate is the IRS Version of the Sweden Treaty (pretty inaccurate)

     September 23, 2022
226. Reviewing Form 5471

     September 9, 2022
227. 16 New Charts Published

     August 30, 2022
228. New IRS Practice Unit - IRC 958 Rules for Determining Stock Ownership

     August 30, 2022
229. 13,000 Regulation Examples

     August 16, 2022
230. Famous Tax Quotes - One Cannot Distribute What One Does Not Have

     July 28, 2022
231. 2022 2nd Quarter Published Expatriates

     July 27, 2022
232. New IRS Practice Unit - 1120-F Delinquent Returns - Filing Deadline Waiver Process

     July 26, 2022
233. Famous Tax Quotes - Tax Legislation Is Not A Promise

     July 25, 2022
234. Internet Birthday --- June 26, 2005

     June 26, 2022
235. Famous Tax Quotes - Turning Square Corners

     June 5, 2022
236. Recent Web Traffic Data

     May 9, 2022
237. 2022 1st Quarter Published Expatriates

     April 25, 2022
238. New IRS Practice Unit - NRA Deferred Compensation

     April 2, 2022
239. New situational chart and video on Income Classification

     March 29, 2022
240. Famous Tax Quotes - Congress Did Not Want To Deal With Citizens As If They Were Still In The Nursery

     March 18, 2022
241. Section 911 Housing Cost Amounts Updated for 2022

     March 9, 2022
242. Update to Zip Codes App and New Heat Maps

     February 24, 2022
243. 2021 Published Expatriates Decreases By 64%

     January 25, 2022
244. 8 New Charts Published

     January 20, 2022
245. New Flowchart – Section 1202 Exclusion for Qualified Small Business Stock ("QSBS")

     January 18, 2022
246. Five New IRS Practice Units

     December 15, 2021
247. New Form 5471, Schedule J Video

     December 3, 2021
248. 2022 Inflation Adjustments for Individuals in the International Tax Arena

     November 16, 2021
249. 2021 3rd Quarter Published Expatriates

     November 12, 2021
250. Two New IRS Practice Units - NRA employee expenses & Form 1040NR for RGS

     October 31, 2021
251. Capitalization Trivia

     September 17, 2021
252. 14 New Charts Published

     September 10, 2021
253. New IRS Practice Unit - FTC (Business) General Principles

     September 2, 2021
254. 2 New IRS Practice Units

     August 26, 2021
255. Two New Heat Maps – AGI by State & Number of Dependents by State

     August 19, 2021
256. Famous Tax Quotes - Taxes Are What We Pay For Civilized Society

     August 14, 2021
257. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     August 4, 2021
258. New IRS Practice Unit: Overview of IRC 987 and Branch Operations in a Foreign Currency

     August 4, 2021
259. 2021 2nd Quarter Published Expatriates

     July 28, 2021
260. IRS Data By Zip Code (Using Python and Flask)

     July 20, 2021
261. 3 New IRS Practice Units

     July 9, 2021
262. New IRS Practice Unit: Concepts of GILTI

     June 18, 2021
263. 13 New Charts Published

     June 15, 2021
264. 130 New Tax Charts – LOB Active Trade or Business Test – Derived In Connection With

     June 8, 2021
265. New IRS Practice Unit: Allocation and Apportionment of Deductions

     May 21, 2021
266. Famous Tax Quotes - A Detour to Crazy Town

     May 17, 2021
267. 2021 1st Quarter Published Expatriates

     April 28, 2021
268. Famous Tax Quotes - Two-Way Street: Downhill for the IRS & Uphill for the Taxpayer

     April 27, 2021
269. New IRS Practice Units - FTC Carryback and Carryover & Liquidating Distributions of a Partner"s Interest in a Partnership

     April 12, 2021
270. US Treaty Limitation on Benefits Status Map

     April 9, 2021
271. AM 2021-002 – Relevance & Check-the-Box Elections

     April 3, 2021
272. Flow-Thru Symbols: An Up-Side-Down "Funnel" Theme

     April 1, 2021
273. Multiple new situational charts published

     April 1, 2021
274. New IRS Practice Unit: 965 Transition Tax

     March 24, 2021
275. Section 911 Housing Cost Amounts Updated for 2021

     March 2, 2021
276. Famous Tax Quotes - Death May Escape the Woes of Life . . .

     February 20, 2021
277. 2020 Sets New Record For Published Expatriates

     February 3, 2021
278. A Brief History of U.S. Tax Expatriation Rules

     January 15, 2021
279. U.K. Pension Lump-Sum Distributions

     November 8, 2020
280. 7 New Tax Charts Published

     November 6, 2020
281. 2021 Inflation Adjustments for Individuals in the International Tax Arena

     November 6, 2020
282. IRS Delinquent International Information Return Submission Procedures Have Been Updated

     November 6, 2020
283. Famous Tax Quotes - Memory Dulled by a Penitentiary Term Served

     November 3, 2020
284. 2020 Third Quarter Published Expatriates – 2020 Is Already the Highest Year Ever

     October 28, 2020
285. Famous Tax Quotes - Fictional Corporate Camouflage

     October 25, 2020
286. 88% of Expatriates Have a Net Worth of Less than $2 Million

     October 18, 2020
287. FBAR Reporting For Indirectly Owned Foreign Bank Accounts

     September 14, 2020
288. A Tax Attorney Uses Python

     September 1, 2020
289. New IRS Practice Unit: Foreign Earned Income

     August 27, 2020
290. 2020 Second Quarter Published Expatriates – Second Highest Quarterly Number Ever

     August 13, 2020
291. U.S. Partnerships Owning CFCs

     August 4, 2020
292. Famous Tax Quotes - No Rational Person . . .

     July 29, 2020
293. Famous Tax Quotes - Backdating of Documents

     July 28, 2020
294. New IRS Practice Units: Reasonable Cause and Good Faith & FTC Limitation

     July 18, 2020
295. Average Price of U.S. Real Estate Sold -- By Country

     July 3, 2020
296. Famous Tax Quotes - Born in Generosity; Debauched in Avarice

     June 30, 2020
297. 5 New Tax Charts Published

     June 17, 2020
298. Free Flowchart - Section 894(c): Hybrid & Reverse Hybrid Entities

     June 9, 2020
299. New IRS Practice Unit: Flow-Through Entities Effects on FTC

     June 4, 2020
300. Two New (& One Updated) IRS Practice Units

     May 9, 2020
301. 2020 First Quarter Published Expatriates –Highest Quarterly Number Ever

     May 7, 2020
302. Three New IRS Practice Units

     April 29, 2020
303. New IRS Practice Unit On The Statute Of Limitations

     April 11, 2020
304. New IRS Practice Unit for "Adjustments for Overwithholding on Form 1042"

     April 8, 2020
305. Rev. Proc. 2020-17 - Exemption From Filing Forms 3520 and 3520-A for Applicable Tax-Favored Foreign Trusts

     March 3, 2020
306. Section 911 Housing Cost Amounts Updated for 2020

     February 25, 2020
307. 11 New Tax Charts

     February 15, 2020
308. 2019 Published Expatriates - Lowest Level in Six Years

     February 10, 2020
309. New IRS Practice Unit – FDAP Statistical Sampling in the Audit of a U.S. Withholding Agent

     January 23, 2020
310. Video - Downward Attribution Form 5471

     January 9, 2020
311. Form 8993 With Graphic of Formulas

     December 26, 2019
312. Famous Tax Quotes - Perhaps Congress Just Stubbed Its Toe

     December 17, 2019
313. Video - Sec. 1446(f) Withholding on Sales of Partnerships Engaged in US Business

     December 12, 2019
314. Famous Tax Quotes - Penalties For Hardheaded Persistence

     December 5, 2019
315. Famous Tax Quotes - Like white asparagus or a blood orange

     December 3, 2019
316. 2020 Inflation Adjustments for Individuals in the International Tax Arena

     November 18, 2019
317. 2019 3rd Quarter Published Expatriates - Lowest Since 4th Quarter 2012

     November 8, 2019
318. Famous Tax Quotes - The Regulations Barely Rocked The Statutory Boat

     October 24, 2019
319. 8 New Charts Of Examples Regarding Classification of Cloud Transactions & Computer Programs

     September 26, 2019
320. 2019 2nd Quarter Published Expatriates

     August 14, 2019
321. Famous Tax Quotes - Forming HoldCo To Acquire Target Is Not Unusual

     August 7, 2019
322. Famous Tax Quotes - A taxpayer"s own documents

     August 4, 2019
323. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 5, 2019
324. 2019 1st Quarter Published Expatriates - 1,019 Names

     May 10, 2019
325. Section 911 Housing Cost Amounts Updated for 2019

     April 17, 2019
326. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2018)

     April 17, 2019
327. New IRS Practice Units published in March

     March 18, 2019
328. 2018 4th Quarter Published Expatriates - A total of 685

     March 12, 2019
329. GILTI Deduction Allowed With 962 Election (Proposed Regulations)

     March 5, 2019
330. Eaton Corp. v. Commr., 152 T.C. No. 2 (2019)

     March 1, 2019
331. New IRS Practice Unit: Creation of a Permanent Establishment (PE) through the Activities of a Dependent Agent in the United States

     January 31, 2019
332. Rental of Real Estate to Yourself

     January 23, 2019
333. Form 5472 Failure to File Penalty Increased to $25,000

     January 14, 2019
334. The "Certification" on Form W-8BEN For Royalties

     January 7, 2019
335. The "Certification" on Form W-8BEN For Interest

     December 31, 2018
336. The "Certification" on Form W-8BEN For Dividends

     December 24, 2018
337. The "Certification" on Form W-8BEN For Services

     December 17, 2018
338. 2019 Inflation Adjustments for Individuals in the International Tax Arena

     November 20, 2018
339. 2018 Third Quarter Published Expatriates – A Total of 1,107

     November 16, 2018
340. New & Updated Draft International Forms

     October 19, 2018
341. Video - GILTI for a CFC With & Without Debt

     October 19, 2018
342. 12 New Tax Charts

     October 18, 2018
343. Famous Tax Quotes - New Batboy Changing the Outcome of the World Series

     October 4, 2018
344. Famous Tax Quotes - That"s How The Cookie Crumbles

     September 22, 2018
345. Video – GILTI in a Minute

     September 17, 2018
346. GILTI Regulations Preamble: Is a 100 Word Sentence Too Long?

     September 13, 2018
347. 13 Charts of Code §958 Regulation Examples

     August 28, 2018
348. 8 Charts of Sec. 965 Transition Tax Regulation Examples

     August 9, 2018
349. 2018 Second Quarter Published Expatriates – A Total of 1,090

     July 31, 2018
350. IRS 2015 Statistics on Form 8805 (Inbound Partnership Investing)

     June 29, 2018
351. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 28, 2018
352. 8 New Tax Charts

     June 28, 2018
353. Famous Tax Quotes - IRS To Enforce Tax Laws; Not To Maximize Tax Receipts

     May 22, 2018
354. 2018 First Quarter Published Expatriates – A Total of 1,099

     May 7, 2018
355. IRS Publication on New Section 965 Transition Tax

     April 14, 2018
356. Famous Tax Quotes - "One Big Wallet"

     April 14, 2018
357. New Video – Attribution Rules for 965 Specified Foreign Corporations

     April 6, 2018
358. Video on IRS FAQs on Section 965 Transition Tax Reporting

     March 20, 2018
359. Video - Form 5471 Attribution from NRA Spouses

     March 9, 2018
360. Qualified Electing Funds ("QEFs") Receiving Qualified Dividend Income

     March 1, 2018
361. Code §965: Individuals Recognizing the Deemed Repatriation in 2017 vs. 2018

     February 14, 2018
362. Update to Video: Global Intangible Low-taxed Income ("GILTI")

     February 10, 2018
363. 2017 Fourth Quarter Published Expatriates – First Annual Decrease in Five Years

     February 8, 2018
364. Andrew Mitchel Speaking on "GILTI" at IFA regional meeting

     February 2, 2018
365. New Video: Form 2555 and the Foreign Earned Income Exclusion

     February 1, 2018
366. TCJA Explanatory Video: Global Intangible Low-taxed Income ("GILTI")

     January 2, 2018
367. Tax Cuts and Jobs Act Explanatory Video: Code §965 Deemed Repatriation from Foreign Corporations

     December 21, 2017
368. New Flowchart – Form 5471 Filing Requirements

     November 13, 2017
369. 2017 Third Quarter Published Expatriates – A Total of 1,376

     November 1, 2017
370. 2018 Inflation Adjustments for Individuals in the International Tax Arena

     October 20, 2017
371. 5 New Tax Charts

     October 20, 2017
372. Famous Tax Quotes - Plodding Through A Tax Court Opinion

     September 24, 2017
373. Famous Tax Quotes - Almost Indistinguishable Lines

     September 18, 2017
374. Withdrawal of Prior Blog Post Regarding Australian Superannuation Funds

     September 14, 2017
375. 5 New Tax Charts

     September 6, 2017
376. Famous Tax Quotes - Anticlimactic Discoveries

     August 24, 2017
377. 5 New Tax Charts

     August 10, 2017
378. Belize IBC Selling Through Amazon FBA

     August 4, 2017
379. 2017 Second Quarter Published Expatriates – Second Highest Ever

     August 2, 2017
380. Tax Court Declines to Follow Rev. Rul. 91-32

     July 20, 2017
381. Famous Tax Quotes - An Unsubstantiated Presumption

     July 6, 2017
382. 5 New Tax Charts

     July 1, 2017
383. Failures to Adjust for Inflation

     June 21, 2017
384. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 11, 2017
385. Famous Tax Quotes - Careful / Close / Extra / Heightened / Rigid / Special / Strict Scrutiny For Related Party Transactions

     June 9, 2017
386. 5 New Tax Charts

     June 2, 2017
387. 5 New Tax Charts

     May 12, 2017
388. 2017 First Quarter Published Expatriates – A Total of 1,313

     May 9, 2017
389. Famous Tax Quotes - Blind Guesses Are Not Good Faith Estimates

     March 30, 2017
390. Famous Tax Quotes - Lower Court Overruling a Higher Court

     March 28, 2017
391. Section 911 Housing Cost Amounts Updated for 2017

     March 24, 2017
392. New Form 5472 Filing Requirements for Foreign-Owned U.S. Disregarded Entities ("FOUSDEs")

     March 6, 2017
393. Being Engaged in U.S. Business Through Independent Agents

     February 27, 2017
394. Famous Tax Quotes - Caligula & Taxes

     February 20, 2017
395. 2016 Fourth Quarter Published Expatriates – New Annual Record

     February 8, 2017
396. 15 New Tax Charts

     February 6, 2017
397. Form 8886: Section 988 Losses >50k Can Be Reportable Transactions

     February 1, 2017
398. Famous Tax Quotes - Congress Does Not Legislate in Logic Puzzles

     January 27, 2017
399. Update to Form 8833 Flowchart (Treaty-Based Return Positions)

     January 27, 2017
400. Free Flowchart – Reg 301.7701-7: Trusts -- Domestic and Foreign

     January 26, 2017
401. Free Flowchart – Reg 301.6114-1 Disclosure of Treaty-Based Return Positions (Form 8833)

     January 23, 2017
402. Increases in Private Letter Ruling Fees for 2017

     January 12, 2017
403. PFIC Mark-to-Market Election Charts & Videos

     January 10, 2017
404. The "Sailing Permit"

     December 28, 2016
405. Final Code §987 Regulations!!

     December 26, 2016
406. 23 New Charts - Code §956 Regulation Examples from T.D. 9792

     December 15, 2016
407. Tax Return Preparation Automation

     December 2, 2016
408. New Videos November 2016

     November 30, 2016
409. 11 New Charts of Foreign Trust Distributions Through Intermediaries

     November 17, 2016
410. 2016 Third Quarter Published Expatriates – Second Highest Ever

     November 9, 2016
411. New Videos - October 2016

     October 31, 2016
412. 2017 Inflation Adjustments for Individuals in the International Tax Arena

     October 27, 2016
413. Over 50 New Situational Charts – Code §7874 Regulation Examples

     October 22, 2016
414. Famous Tax Quotes - Source of Income When Business Is Begun In One Country And Ended In Another

     October 19, 2016
415. New Videos - September 2016

     September 30, 2016
416. New Videos - August 2016

     September 13, 2016
417. Famous Tax Quotes - Clapping With One Hand

     August 26, 2016
418. Free Flowchart – Reg. 1.937-1 – Bona Fide Residency in a U.S. Possession

     August 25, 2016
419. Famous Tax Quotes - King Minos" Labyrinth

     August 3, 2016
420. New Videos - July 2016

     July 29, 2016
421. 2016 Second Quarter Published Expatriates

     July 28, 2016
422. Substantiation of Deductions to Foreign Contractors

     July 22, 2016
423. New Videos - June 2016

     June 30, 2016
424. Free Flowchart - Form 5472 Filing Requirements (Code §§6038A and 6038C)

     June 7, 2016
425. New Videos - May 2016

     May 31, 2016
426. Famous Tax Quotes - "Tax Language"

     May 19, 2016
427. Tax Treaty Limitation on Benefits ("LOB") & Form W8-BEN-E

     May 10, 2016
428. Over 1,000 Published Expatriates in 2016 Q1 - The New Normal

     May 4, 2016
429. New Videos - April 2016

     April 29, 2016
430. Encouraging Foreign Investment - A Distorted U.S. Tax Policy

     April 3, 2016
431. New Videos - March 2016

     March 31, 2016
432. Section 911 Housing Cost Amounts Updated for 2016

     March 22, 2016
433. Rev. Rul. 2016-8: Tax Aspects of the Cuban Thaw

     March 10, 2016
434. New Videos - February 2016

     March 1, 2016
435. Charts of Examples in Rev. Proc. 91-55: Form 5472 & Direct and Ultimate Indirect 25% Shareholders

     February 22, 2016
436. New Expatriate Record for 2015 – Nearly 4,300 Expatriations

     February 5, 2016
437. Famous Tax Quotes - Where to Draw the Line

     January 29, 2016
438. Sale of Stock of a CFC – Example of the Potential Benefit of Code §1248(b)

     January 26, 2016
439. Rev. Rul. 56-613 Video (Failed B Reorg - Indirect Control)

     January 24, 2016
440. Flowchart - Section 267(a)(2) & (3) Related Party Matching Rules

     December 22, 2015
441. FAST Act Passport Revocation Provisions

     December 11, 2015
442. The Escalation of Offshore Penalties Over the Last 20 Years

     November 2, 2015
443. 2015 Third Quarter Published Expatriates – A Record High

     October 26, 2015
444. 2016 Inflation Adjustments for Individuals in the International Tax Arena

     October 23, 2015
445. FATCA Overview - Crawford v. U.S. Dep't of the Treasury

     October 17, 2015
446. Famous Tax Quotes - The Basic Structure of the Internal Revenue Code

     October 5, 2015
447. Is the IRS Missing Names From Its Quarterly Publication of Expatriates?

     September 16, 2015
448. Chart of Rev. Rul. 84-125 - Accrual of Foreign Tax Credit on Contested Liability & 10 Year Limitations Period

     September 7, 2015
449. Charts of 704(c) Traditional Method & Trad. Meth. With Curative Allocations

     September 5, 2015
450. Charts of Examples in Code §6038A Regulations: Form 5472 Reporting Requirements

     August 25, 2015
451. Flowchart - PFIC Mark-to-Market Elections

     August 20, 2015
452. Recent Publications

     August 14, 2015
453. New FBAR Due Date

     August 12, 2015
454. 2015 - 2016 IRS Priority Guidance Plan - International Issues

     August 11, 2015
455. 2015 Second Quarter Published Expatriates – Lowest in Years

     July 30, 2015
456. Video: U.S. Taxation of Foreign Vacation Homes Held Thru Entities

     June 29, 2015
457. Application of PFIC Look-Through Rules to Foreign Corporation with U.S. Subsidiaries

     June 18, 2015
458. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 9, 2015
459. When an Active NFFE Can Be a Passive NFFE

     June 3, 2015
460. Charts of Rev. Rul. 2015-09 & Rev. Rul. 2015-10

     May 11, 2015
461. The Exodus Continues (2015 1st Quarter Published Expatriates)

     May 7, 2015
462. Recognition of Losses on Dispositions of PFICs

     April 14, 2015
463. Famous Tax Quotes - Muddled Tax Return Reporting

     April 2, 2015
464. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2014)

     March 27, 2015
465. JCT Excellent Summary of U.S. Cross-Border Tax Rules

     March 18, 2015
466. 2014 - More Expatriations Than Ever

     February 10, 2015
467. New Private Letter Ruling Fees

     February 5, 2015
468. Charts of Examples in Notice 2014-52

     February 5, 2015
469. A Reminder for Green Card Holders Living Outside the U.S.

     January 3, 2015
470. Famous Tax Quotes - Residence - As Many Colors As Joseph's Coat

     January 1, 2015
471. McLaulin – Failed Spin-Off (Situational Chart)

     December 29, 2014
472. IRS International Practice Units

     December 23, 2014
473. Video: Tax as a Percentage of GDP: 1965 to 2013

     December 17, 2014
474. Famous Tax Quotes - A Rose is a Rose is a . . .

     December 13, 2014
475. Chart of PLR With Outbound 332 Liquidation

     December 7, 2014
476. Why U.S. Companies Invert Video

     December 3, 2014
477. International PLRs of Note for the 46th and 47th week of 2014

     December 2, 2014
478. Willful vs. Non-Willful FBAR Violations

     November 22, 2014
479. IRS Documents Released Under Freedom of Information Act

     November 20, 2014
480. New Rules for Canadian RRSPs & RRIFs

     November 2, 2014
481. 2015 Inflation Adjustments for Individuals in the International Tax Arena

     November 2, 2014
482. 2014 Third Quarter Published Expatriates – Third Highest Ever

     October 24, 2014
483. Famous Tax Quotes - Taxing Citizens by Reason of Citizenship

     October 3, 2014
484. Famous Tax Quotes - "Maxims" & "Minims"

     September 28, 2014
485. Payments to Foreign Contractor Entities: Form W-8BEN-E

     September 22, 2014
486. International PLRs of Note for the 38th week of 2014

     September 22, 2014
487. Famous Tax Quotes - "Laughable" Test - All Caps Spelling

     September 10, 2014
488. International PLRs of Note for the 36th week of 2014

     September 5, 2014
489. International PLRs of Note for the 34th week of 2014

     August 22, 2014
490. Chart of PLR 201432002: No Inversion as a Result of an F Reorganization & an IPO

     August 19, 2014
491. Famous Tax Quotes - From the Brow of Zeus

     August 15, 2014
492. International PLRs of Note for the 32nd week of 2014

     August 14, 2014
493. 2014 Second Quarter Published Expatriates

     August 6, 2014
494. Charts of Examples in Notice 2014-44

     July 28, 2014
495. Past IRS Memoranda on the Singapore Central Provident Fund

     July 4, 2014
496. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 13, 2014
497. Chart of CCA 201420017: Code §956: Funneling of Loan through One CFC Partner is Disregarded

     May 20, 2014
498. 2014 First Quarter Published Expatriates - Second Highest Ever

     May 1, 2014
499. Section 911 Housing Cost Amounts Updated for 2014

     April 15, 2014
500. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2013)

     March 27, 2014
501. Chart of PLR 201411006 - Combination of Two Consolidated Groups Owned by Foreign Parent

     March 18, 2014
502. International PLRs for the 10th week of 2014

     March 13, 2014
503. Chart of Central de Gas de Chihuahua

     February 22, 2014
504. International PLRs for the 7th and 8th week of 2014

     February 22, 2014
505. Famous Tax Quotes - Can"t Have Your Cake and Eat It Too

     February 22, 2014
506. Famous Tax Quotes - Hiding the Pea

     February 20, 2014
507. Statute of Limitations for Foreign-Related Items

     February 18, 2014
508. Famous Tax Quotes - Expatriation is a Serious Act

     February 16, 2014
509. Charts of Examples in §1361 Regulations: Termination of QSub Elections

     February 14, 2014
510. Quarterly List of Expatriates: Source of Data

     February 12, 2014
511. 2013 Expatriations Increase by 221%

     February 6, 2014
512. FBAR Video

     February 5, 2014
513. International PLRs for the 5th week of 2014

     February 5, 2014
514. International PLRs for the 4th week of 2014

     January 27, 2014
515. Charts of Examples in §355 Regulations: Continuity of Interest

     January 24, 2014
516. Charts of Examples in New PFIC Annual Filing Requirement Regulations (Form 8621)

     January 15, 2014
517. International PLRs for the 2nd week of 2014

     January 12, 2014
518. New Free Flowchart at Tax-Charts.com : Code §357 Assumption of Liabilities in Certain Exchanges

     January 9, 2014
519. New Rules for PFIC Annual Filing (Form 8621)

     January 8, 2014
520. International PLRs for the 1st week of 2014

     January 3, 2014
521. International PLRs for the 52nd week of 2013

     December 31, 2013
522. Free Simplified Section 351 Exchange Flowchart

     December 26, 2013
523. International PLRs for the 51st week of 2013

     December 20, 2013
524. Change to Weekly PLR Posts

     December 19, 2013
525. Famous Tax Quotes - Morass of United States Tax Laws

     December 17, 2013
526. International PLRs for the 50th week of 2013

     December 16, 2013
527. Famous Tax Quotes - Earnings and Profits

     December 15, 2013
528. Dover - Check-the-Box and Sale Video

     December 8, 2013
529. Form 5471, Schedule J Video

     December 7, 2013
530. International PLRs for the 49th week of 2013

     December 6, 2013
531. New Resource Page: Monetary Penalties for Failure to File Common U.S. International Tax Forms

     December 4, 2013
532. Chart of Rev. Rul. 66-79 - Deductibility of Contributions to "Foreign Feeder" Charity

     December 2, 2013
533. Famous Tax Quotes - Precedent

     December 1, 2013
534. International PLRs for the 48th week of 2013

     November 29, 2013
535. Chart of Rev. Rul. 63-252 - Deductibility of Contributions to "Foreign Feeder" Charities

     November 27, 2013
536. New Addition to the Blog: Resource Pages

     November 26, 2013
537. International PLRs for the 47th week of 2013

     November 22, 2013
538. International PLRs for the 46th week of 2013

     November 22, 2013
539. Chart of Rev. Rul. 71-336 - Corporation as Conduit for Exchange of Stock a Taxable Transaction

     November 16, 2013
540. International PLRs for the 45th week of 2013

     November 15, 2013
541. Famous Tax Quotes - If Rube Goldberg Had Been a Tax Accountant

     November 15, 2013
542. 2013 Third Quarter Published Expatriates

     November 13, 2013
543. Chart of Rev. Rul. 67-192 - Section 367 Triggers Gain, but not Loss, in Outbound 351 Transaction

     November 12, 2013
544. Chart of Chief Counsel Advice AM2013-006: §302 Redemption Reduces CFC's Pool of Foreign Income Taxes

     November 9, 2013
545. International PLRs for the 44th week of 2013

     November 8, 2013
546. Chart of Rev. Rul. 70-253 - Payment of Compensation to Partnership Employee Deductible by Partner under §162(a)

     November 5, 2013
547. 2014 Inflation Adjustments for Individuals in the International Tax Arena

     November 4, 2013
548. Chart of Rev. Rul. 66-365 - Solely for Voting Stock: Cash in Lieu of Fractional Shares

     November 4, 2013
549. International PLRs for the 43rd week of 2013

     November 2, 2013
550. International PLRs for the 42nd week of 2013

     November 2, 2013
551. International PLRs for the 41st week of 2013

     October 31, 2013
552. Chart of PLR 201340010 - Manufacturing Exception to FBCSI - Growing Activities can be Production Activities

     October 23, 2013
553. International PLRs for the 40th week of 2013

     October 23, 2013
554. Famous Tax Quotes - The Form of a Transaction Can Control Tax Consequences

     October 22, 2013
555. Famous Tax Quotes - The IRM Holds No Legal Significance

     October 11, 2013
556. Chart of PLR 201324005 - ADS Not Required for Possession Located Property Held Through Partnership

     October 2, 2013
557. International PLRs for the 39th week of 2013

     September 27, 2013
558. Chart of Rev. Rul. 90-76 - Foreign Corporations: Liquidating Distributions of USRPIs

     September 26, 2013
559. Chart of PLR 201328003 - Deemed Distribution and Contribution with Circular Flow of Cash

     September 25, 2013
560. International PLRs for the 38th week of 2013

     September 23, 2013
561. Famous Tax Quotes - [Un]Comfortable Degree of Accuracy

     September 22, 2013
562. New Attorney Announcement - Ryan E. Dunn

     September 20, 2013
563. Situational Chart of Rev. Rul. 89-103 - Stapling of Interests Triggers Inbound "F" Reorganization

     September 17, 2013
564. International PLRs for the 37th week of 2013

     September 13, 2013
565. Situational Chart of Rev. Rul. 58-422 - Merger an "F" Reorg & Two 332 Liquidations

     September 13, 2013
566. Situational Chart of Rev. Rul. 70-434 - Spin-Off & "B" Reorganization

     September 11, 2013
567. Situational Charts of "F" Reorganizations of "S" Corporations

     September 9, 2013
568. International PLRs for the 36th week of 2013

     September 6, 2013
569. International PLRs for the 35th week of 2013

     September 5, 2013
570. International PLRs of the 34th week of 2013

     September 5, 2013
571. International PLRs of the 33rd week of 2013

     September 5, 2013
572. International PLRs of the 32nd week of 2013

     September 5, 2013
573. International PLRs of the 31st week of 2013

     September 5, 2013
574. International PLRs of the 30th week of 2013

     September 5, 2013
575. International PLRs of the 29th week of 2013

     September 5, 2013
576. International PLRs of the 28th week of 2013

     September 5, 2013
577. Famous Tax Quotes - Double Taxation Cannot Always Be Avoided

     August 30, 2013
578. Situational Charts of Examples 8 and 9 of Treas. Reg. §1.1361-5(b)(3) - Terminations of Qsub Elections

     August 29, 2013
579. International PLRs of the 27th week of 2013

     August 29, 2013
580. International PLRs of the 26th week of 2013

     August 29, 2013
581. International PLRs of the 25th week of 2013

     August 29, 2013
582. International PLRs of the 24th week of 2013

     August 29, 2013
583. Famous Tax Quotes - "Bureaucrats"

     August 28, 2013
584. Famous Tax Quotes - Separate Entity Doctrine

     August 28, 2013
585. International PLRs of the 23rd week of 2013

     August 26, 2013
586. International PLRs of the 22nd week of 2013

     August 26, 2013
587. International PLRs of the 21st week of 2013

     August 25, 2013
588. International PLRs of the 20th week of 2013

     August 25, 2013
589. International PLRs of the 19th week of 2013

     August 25, 2013
590. Situational Chart of Rev. Rul. 78-401 - No Meaningful Reduction In The Shareholder's Proportionate Interest

     August 24, 2013
591. International PLRs of the 18th week of 2013

     August 23, 2013
592. International PLRs of the 17th week of 2013

     August 22, 2013
593. International PLRs for the 16th week of 2013

     August 21, 2013
594. International PLRs of the 15th week of 2013

     August 20, 2013
595. International PLRs of the 14th week of 2013

     August 19, 2013
596. International PLRs of the 13th week of 2013

     August 18, 2013
597. International PLRs of the 12th week of 2013

     August 16, 2013
598. IRS Rules Commission Income From Sales is Not FBCSI

     August 16, 2013
599. Number of Expatriates Skyrockets Again (Second Quarter of 2013)

     August 9, 2013
600. Tax Textbook Built Into Lamp

     July 21, 2013
601. Mandatory Electronic Filing for FBARs Coming Soon

     June 13, 2013
602. Daly v. Commr. - Abode Was in the U.S. - No Foreign Earned Income Exclusion Allowed

     June 12, 2013
603. Fideicomisos/Mexican Land Trusts are Not Trusts (Finally)

     June 6, 2013
604. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 1, 2013
605. Inbound Overview Flowchart (for Sale)

     May 10, 2013
606. Barnes Group - Structured Repatriation Was a Dividend

     May 10, 2013
607. Q1 2013 - Highest Quarterly Number of Expatriates Ever (But . . . )

     May 8, 2013
608. Section 911 Housing Cost Amounts Updated for 2013

     May 6, 2013
609. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2012)

     April 12, 2013
610. International PLRs & CCA of the 11th week of 2013

     March 22, 2013
611. International PLRs of the 10th week of 2013

     March 21, 2013
612. International PLRs of the 9th week of 2013

     March 4, 2013
613. International PLRs of the 8th week of 2013

     February 26, 2013
614. International PLR of the 7th week of 2013

     February 20, 2013
615. 48% Decrease in Number of Expatriates for 2012

     February 14, 2013
616. FATCA, NFFEs, and Draft W-8BEN-E - Unnecessary Complexity

     February 13, 2013
617. International PLR of the 6th week of 2013

     February 11, 2013
618. PLRs of the 5th week of 2013

     February 1, 2013
619. International PLRs of the 4th week of 2013

     January 26, 2013
620. Form 5471 Videos

     January 25, 2013
621. International PLRs of the 3rd week of 2013

     January 19, 2013
622. International PLRs for the 2nd week of 2013

     January 19, 2013
623. Free Section 351 Exchange Flowchart

     January 18, 2013
624. International PLRs of the 1st week of 2013

     January 4, 2013
625. Senate Fiscal Cliff Bill Includes Retroactive Reinstatement of CFC Look-Thru Rule

     January 1, 2013
626. International PLRs of the 52nd Week of 2012

     December 28, 2012
627. International PLRs & CCA"s of the 51st week of 2012

     December 27, 2012
628. International PLRs for the 50th week of 2012

     December 20, 2012
629. Teaching International Tax at Quinnipiac University School of Law

     December 20, 2012
630. International PLRs of the 49th week of 2012

     December 13, 2012
631. Doctrine of Constructive Receipt

     December 13, 2012
632. International PLRs of the 48th week of 2012

     November 30, 2012
633. Summary of Form 8938 Filing Thresholds

     November 28, 2012
634. International PLRs of the 47th week of 2012

     November 24, 2012
635. International PLRs of the 46th week of 2012

     November 24, 2012
636. International PLRs of the 45th week of 2012

     November 24, 2012
637. IRS Rules that Mexican Fideicomiso is Not a Trust

     November 15, 2012
638. International PLRs of the 44th week of 2012

     November 10, 2012
639. Graphic on Inbound & Outbound

     November 7, 2012
640. International PLRs of the 43rd Week of 2012

     November 5, 2012
641. International PLRs of the 42nd week of 2012

     November 5, 2012
642. International PLRs for the 41st week of 2012

     November 5, 2012
643. International PLRs of the 38th, 39th & 40th weeks of 2012

     November 3, 2012
644. Expatriates for the Third Quarter of 2012

     November 1, 2012
645. USD School of Law - Procopio International Tax Institute

     October 26, 2012
646. 2013 Inflation Adjustments for Individuals in the International Tax Arena

     October 23, 2012
647. Repatriate Now? (Before the Bush Tax Cuts Expire)

     October 19, 2012
648. Form 1099 for Payments to Foreign Contractors for Services?

     October 7, 2012
649. Senate Committee Video Testimony - Offshore Profit Shifting

     October 1, 2012
650. International PLRs of the 37th week of 2012

     September 15, 2012
651. 8th Annual USD School of Law-Procopio International Tax Law Institute (Oct. 25th & 26th)

     September 10, 2012
652. International PLRs of the 36th week of 2012

     September 8, 2012
653. Famous Tax Quotes - Accounting Firm "Screw Up"

     September 5, 2012
654. International PLR of the 35th week of 2012

     September 4, 2012
655. Partnership Definition

     September 4, 2012
656. Gratuitous Links to Local Visiting Nurses Association

     September 2, 2012
657. Canada & U.S. to Apply the Authorized OECD Approach ("AOA") for Attribution of Business Profits

     September 2, 2012
658. Belgian Municipal and Conurbation Income Taxes are Covered by the Treaty

     August 31, 2012
659. International PLRs of the 34th week of 2012

     August 25, 2012
660. International PLR of the 33rd week of 2012

     August 25, 2012
661. International PLRs of the 32nd week of 2012

     August 25, 2012
662. International PLRs & CCA of the 31st week of 2012

     August 24, 2012
663. International PLRs of the 30th week of 2012

     August 24, 2012
664. 189 Published Expatriates for Q2 of 2012

     August 2, 2012
665. Joint FATCA Implementation Statements

     July 21, 2012
666. International PLRs of the 29th week of 2012

     July 21, 2012
667. International PLRs of the 28th week of 2012

     July 21, 2012
668. International PLRs of the 26th week of 2012

     July 21, 2012
669. International PLR of the 25th week of 2012

     July 21, 2012
670. International PLRs of the 24th week of 2012

     June 16, 2012
671. International PLRs of the 23rd week of 2012

     June 12, 2012
672. International PLRs of the 22nd week of 2012

     June 12, 2012
673. International PLR of the 21st week of 2012

     June 11, 2012
674. International PLRs of the 20th week of 2012

     June 11, 2012
675. Links to Expatriate Lists

     June 8, 2012
676. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 2, 2012
677. Update on 1997 Expatriation Data

     June 1, 2012
678. Example of a Mini-Eduardo Saverin

     May 18, 2012
679. Book Review: Transfer Pricing Answer Book 2012

     May 15, 2012
680. International PLRs of the 19th week of 2012

     May 14, 2012
681. All Cash D Reorganization Video - Example 16, Loss of Basis

     May 9, 2012
682. All Cash D Reorganization Video

     May 2, 2012
683. 460 Published Expatriates for Q1 of 2012

     April 29, 2012
684. International PLRs of the 15th and 16th Weeks of 2012

     April 23, 2012
685. Spin-Off to Foreign Parent Video

     April 21, 2012
686. Aiken Industries Video

     April 17, 2012
687. Brazilian tax package

     April 11, 2012
688. International PLRs of the 14th week of 2012

     April 10, 2012
689. International PLRs of the 13th week of 2012

     April 1, 2012
690. International PLRs of the 12th week of 2012

     March 29, 2012
691. B Reorganization Video

     March 24, 2012
692. 1997 Had More U.S. Expatriations Than 2011

     March 19, 2012
693. International PLRs of the 10th week of 2012

     March 16, 2012
694. Attorney-Client Privilege Flowchart

     March 15, 2012
695. International PLRs / CCAs of the 8th week of 2012

     March 2, 2012
696. 10 Free New Tax Charts (Feburary 2012)

     March 2, 2012
697. Section 911 Housing Cost Amounts Updated for 2012

     February 14, 2012
698. International PLRs / CCAs of the 6th week of 2012

     February 12, 2012
699. Famous Tax Quotes - Same Boat But Another Ocean

     February 5, 2012
700. International PLRs / CCAs of the 5th week of 2012

     February 3, 2012
701. Number of Expatriates for 2011

     February 2, 2012
702. International PLRs / CCAs of the 4th week of 2012

     January 30, 2012
703. International Aspects of Mitt Romney"s 2010 Tax Return

     January 27, 2012
704. International PLRs of the 3rd week of 2012

     January 26, 2012
705. Uncompensated Use of Foreign Trust Property

     January 25, 2012
706. Income Accruing in Foreign Retirement Plans

     January 22, 2012
707. New FBAR (Again) - Email Your Questions

     January 20, 2012
708. International PLRs of the 2nd week of 2012

     January 20, 2012
709. International PLRs of the 1st week of 2012

     January 6, 2012
710. International PLRs of the 52nd Week of 2011

     December 31, 2011
711. International PLRs of the 51st Week of 2011

     December 23, 2011
712. This Post Has Been Updated

     December 23, 2011
713. International PLRs of the 50th Week of 2011

     December 20, 2011
714. Code §951 Inclusions Are Not Qualified Dividend Income

     December 17, 2011
715. International PLRs of the 49th Week of 2011

     December 12, 2011
716. Loan With "Kicker" is a USRPI

     December 8, 2011
717. International PLRs of the 47th Week of 2011

     November 26, 2011
718. International PLRs of the 46th Week of 2011

     November 18, 2011
719. Subpart F Income

     November 14, 2011
720. International PLRs of the 43rd Week of 2011

     November 11, 2011
721. International PLRs of the week

     October 25, 2011
722. 2012 Inflation Adjustments for Individuals in the International Tax Arena

     October 24, 2011
723. New Brunswick Premier Caught in U.S. Tax Net

     October 3, 2011
724. Goosen v. Commr. - Golfer Endorsement Fees

     August 23, 2011
725. Notice 2011-64: Countries Qualifying for Reduced Dividend Tax Rates

     August 18, 2011
726. Q2 of 2011 Had the Second Highest Number of "Published Expatriates"

     August 17, 2011
727. U.K. Remittance Basis Charge ("RBC") is a Creditable Tax

     August 15, 2011
728. Dagres - Ordinary Loss for Bad Debt of Private Equity Fund Manager

     August 12, 2011
729. Double Taxation on Services

     July 26, 2011
730. The "Repatriation IRA" [To Stimulate the Economy]

     July 7, 2011
731. Is the Limitation On Benefits Provision in the Proposed Hungary Treaty Too Complex?

     July 7, 2011
732. Free Section 736 Flowchart

     July 6, 2011
733. YouTube Video on Busted Section 351 Exchanges

     June 29, 2011
734. Flowchart of LOB Article of Chile-U.S. Income Tax Treaty

     June 27, 2011
735. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 24, 2011
736. Famous Tax Quotes - Transactions Between Related Parties Merit Extra Scrutiny

     June 23, 2011
737. IRS Delays Annual Reporting for Foreign Financial Assets and P.F.I.C.s

     June 21, 2011
738. This Post Has Been Updated

     June 17, 2011
739. Additional Extension for Pre-2010 Signature Authority Only FBARs

     June 16, 2011
740. Two New Flowcharts on Tax-Charts.com

     June 13, 2011
741. U.S. Citizens Continue to Renounce

     June 10, 2011
742. 10 Free New Tax Charts (June 2011)

     June 10, 2011
743. Offshore Structure to Hold Iraqi Dinars?

     May 23, 2011
744. Flowchart of Rev. Proc. 93-27

     May 12, 2011
745. Doctrine of Cloth[e]ing

     May 2, 2011
746. Should "goodwill" be one word or two words?

     March 31, 2011
747. IRS Reporting of Bank Interest Paid to NRAs

     March 29, 2011
748. Famous Tax Quotes - Valuation Is Not an Exact Science

     March 22, 2011
749. NPR Podcast on Double Irish Structure

     March 18, 2011
750. Famous Tax Quotes - Very definitely . . . probably

     March 17, 2011
751. Famous Tax Quotes - Congress Can "label a thing income and tax it"

     March 9, 2011
752. Number of Expatriates More Than Doubles

     March 4, 2011
753. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2010)

     February 28, 2011
754. 30% Tax for Interest Paid on Foreign Margin Account of U.S. Resident

     February 23, 2011
755. Famous Tax Quotes - Seduced by a Siren Song of Symmetry

     February 18, 2011
756. CCA 201106007 - Investments in U.S. Property - Intangibles

     February 14, 2011
757. Famous Tax Quotes - Drawing Lines

     February 10, 2011
758. PLR 201105011 Allows Re-Election of Revoked Code §911 Foreign Earned Income Exclusion

     February 6, 2011
759. Section 911 Housing Cost Amounts Updated for 2011

     February 2, 2011
760. 10 Free New Tax Charts (Jan. 2011)

     January 20, 2011
761. Terminology for Hybrid Entities & Hybrid Instruments

     January 19, 2011
762. Famous Tax Quotes - Too Good To Be True . . .

     December 28, 2010
763. Famous Tax Quotes - A "Hat Problem"

     December 27, 2010
764. Google Ngrams for Selected Tax Terms

     December 21, 2010
765. Code § 954(c)(6) C.F.C. Look-Thru Rule Retroactive Reinstatement

     December 17, 2010
766. 10 Free New Tax Charts

     December 7, 2010
767. Famous Tax Quote #37 - Is Fido a dog?

     December 7, 2010
768. Famous Tax Quote #36 - Differences in Degree vs. Differences in Kind

     November 11, 2010
769. International Financial Scams - Overseas Investments, Lotteries, Inheritances, Gifts, etc.

     November 2, 2010
770. Famous Tax Quote #35 - Foresight and Planning

     October 31, 2010
771. 2011 Inflation Adjustments for Individuals in the International Tax Arena

     October 28, 2010
772. Two New Flowcharts

     October 27, 2010
773. Google"s Use of Double Irish Structure

     October 21, 2010
774. Expatriations Continue Upward Trend

     October 21, 2010
775. OECD Commentary on Electronic Commerce for Permanent Establishments

     October 18, 2010
776. Free Flowchart of Rev. Proc. 2009-41

     October 12, 2010
777. Famous Tax Quote #34 - A Word is Not a Crystal

     September 24, 2010
778. Famous Tax Quote #33 - A melody is more than the notes

     September 20, 2010
779. Software Classification Flowchart

     September 16, 2010
780. Famous Tax Quote #32 - Change in the tax laws is a way of life

     September 3, 2010
781. Tax Crimes, Tax Fraud, Tax Schemes

     August 30, 2010
782. Famous Tax Quote #31 - If Pigs Had Wings, They Could Fly

     August 25, 2010
783. Famous Tax Quote #30 - A Judicial Moon

     August 17, 2010
784. New Section 956 Foreign Tax Credit Blending Rule

     August 13, 2010
785. Should Congress Force An Accounting Rule Change?

     July 28, 2010
786. Hybrid Entities and Reverse Hybrid Entities

     July 27, 2010
787. Famous Tax Quote #29 - Taxing Corporate Distributions

     July 4, 2010
788. Famous Tax Quote #28 - Purpose of Subpart F Income

     June 27, 2010
789. What is a "check-the-box" election?

     June 25, 2010
790. Famous Tax Quote #27 - All of life is a risk

     June 13, 2010
791. Famous Tax Quote #26 - Business Purpose / Economic Substance

     June 6, 2010
792. U.S. Model Treaty: Limitation on Benefits Flowchart

     June 3, 2010
793. Famous Tax Quote #25 - Broker vs. Dealer

     May 30, 2010
794. Covered Expatriate Flowchart

     May 27, 2010
795. Subpart F Income Partnership Blocker Update

     May 25, 2010
796. Famous Tax Quote #24 - Name for a Partnership With No Business Purpose

     May 23, 2010
797. Double Irish Structure - Time for a New Tax Penalty?

     May 20, 2010
798. Pensions Under the Belgium-U.S. Income Tax Treaty

     May 18, 2010
799. Famous Tax Quote #23 - Motives Immaterial in a Code § 368(a)(1)(D) Reorganization

     May 16, 2010
800. Canada-U.S. Treaty - Guidance on Deemed Sale/Purchase Election

     May 13, 2010
801. Famous Tax Quote #22 - Redemption as a Step in a Reorganization

     May 11, 2010
802. Foreign "EZ Pass" --- A Foreign Financial Account?

     May 7, 2010
803. Sourcing By Analogy

     May 2, 2010
804. Famous Tax Quote #21 - The Words Dance Before My Eyes

     May 2, 2010
805. New PFIC Annual Reporting Rules

     April 7, 2010
806. Beware Gifts to Non-Citizen Spouses

     April 2, 2010
807. New Foreign Asset Disclosure Rules Enacted

     March 20, 2010
808. A Circumvention of the Spirit of the Law?

     March 19, 2010
809. U.S. Expatriations Skyrocket

     March 1, 2010
810. Guarantee Fees Analogized as Services

     February 18, 2010
811. IRS Rulings on Manufacturing Branch Rule

     February 11, 2010
812. Cash D Reorganizations & the Meaningless Gesture Doctrine

     February 11, 2010
813. Famous Tax Quote #20 - Tax Reduction Is Not Evil

     February 10, 2010
814. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2009)

     February 5, 2010
815. Famous Tax Quote #19 - How many legs does a dog have?

     February 3, 2010
816. 97th Anniversary of the 16th Amendment

     February 3, 2010
817. Offshore Bearer Bonds

     January 8, 2010
818. Alice in Wonderland

     December 31, 2009
819. Sourcing Rules for Telecoms" International Communications Income

     December 20, 2009
820. Famous Tax Quote #18 - "Dummy" Corporations

     December 16, 2009
821. Famous Tax Quote #17 - Taxation depends on actual events

     December 8, 2009
822. Famous Tax Quote #16 - Taxation is Not Cuneiform.

     December 5, 2009
823. Famous Tax Quote #15 - Simple Expedient of Drawing Up Papers

     December 2, 2009
824. Liechtenstein Anstalts & Stiftungs

     November 24, 2009
825. Expatriations on the Rise Again

     November 19, 2009
826. Famous Tax Quote #14 - Mere Formalisms

     November 16, 2009
827. Famous Tax Quote #13 - Anticipatory Assignment

     November 13, 2009
828. Famous Tax Quote #12 - Income Is Taxed to The Earner

     November 4, 2009
829. Overseas Inheritance Scam: Tax Certificate for Wire Transfer

     October 14, 2009
830. FBAR Reporting for Foreign Mutual Funds

     September 18, 2009
831. Three Manufacturing Tests Under Code § 954(d) & the Manufacturing Branch Rules

     September 11, 2009
832. Green Card Holders Living Outside the U.S.

     September 10, 2009
833. Schering-Plough Corp. v. U.S.

     September 5, 2009
834. Famous Tax Quote #11 - Exalting Form Over Substance

     September 4, 2009
835. IRS Extends Due Date for Late Check-the-Box Elections

     September 3, 2009
836. Famous Tax Quote #10 - Meaningless Gesture

     September 2, 2009
837. Famous Tax Quote #9 - Origin of All Events Test

     August 28, 2009
838. Widely Held vs. Closely Held

     August 26, 2009
839. "Inbound" & "Outbound"

     August 24, 2009
840. Free Code § 302 Redemption Flowchart

     August 19, 2009
841. Famous Tax Quote #8 - Tax Rules Don't Necessarily Make Sense

     August 14, 2009
842. Famous Tax Quote #7 - Contingent Liabilities

     August 10, 2009
843. Tax Chart Shape & Color Conventions

     July 31, 2009
844. Famous Tax Quote #6 - Presumption of Correctness

     July 30, 2009
845. Foreign Deferral Matching Principle

     July 20, 2009
846. Famous Tax Quotes #4 & #5 - No Patriotic Duty to Increase Taxes

     July 14, 2009
847. Famous Tax Quote #3 - Deductions Legislative Grace

     July 10, 2009
848. Famous Tax Quote #2 - What Actually Occurred

     July 5, 2009
849. Famous Tax Quote #1 - Straight Path / Devious Path

     July 3, 2009
850. Qualified Business Units (QBUs)

     June 30, 2009
851. IRS Additional FAQs Regarding Filing of FBAR and other Cross-Border Tax Forms

     June 26, 2009
852. UBS Client Pleads Guilty to Filing False Tax Return

     June 25, 2009
853. Branch Rule Complexity Continued

     May 12, 2009
854. Branch Rule Complexity

     May 12, 2009
855. Deemed Permanent Establishment, But Not Carrying On Business

     May 1, 2009
856. Offshore Asset Protection Misconceptions

     April 28, 2009
857. IRS Finally Publishes 2008 Form 8804

     March 22, 2009
858. Modifications to Section 367 in Outbound Section 304 Transactions

     February 27, 2009
859. "Unrelated" Financial Institution Under U.S.-Australia Income Tax Treaty

     February 2, 2009
860. Treaty Limits on Reduced Dividend Withholding Rates for U.S. Mutual Funds

     December 31, 2008
861. Ireland - What"s Not to Like?

     December 2, 2008
862. Foreign Bank Secrecy & Tax Evasion

     November 26, 2008
863. Irish Times: "Obama could be bad for Ireland"

     October 27, 2008
864. Treasury Department"s Billion Dollar Tax Bailout for Banks By Fiat

     October 1, 2008
865. Poor Grammar in Drafting of CFC Statutes

     September 22, 2008
866. Section 367 - Exceptions Upon Exceptions

     August 22, 2008
867. IRS Shuts Down Another Repatriation Technique

     August 8, 2008
868. New Tax Charts

     July 18, 2008
869. 5 Charts of Non-U.S. Tax Cases

     July 10, 2008
870. Chart of Killer Forward Triangular Merger

     July 7, 2008
871. IRS to Scrutinize International Transactions of Smaller Companies

     July 6, 2008
872. New Expatriation Rules for High Net Worth Individuals

     June 29, 2008
873. Treasury Issues Regulations to Close Repatriation Loophole

     June 22, 2008
874. U.S. "State" Tax Residency (Domicile)

     June 1, 2008
875. Canadian Outbound Taxation

     May 25, 2008
876. Treaty Shopping & Anti-Treaty Shopping

     May 18, 2008
877. Bulgarian Aktsionerno Druzhestvo Added To Per Se Corporation List

     May 4, 2008
878. Inheriting Foreign Real Estate Inside a Foreign Corporation

     April 6, 2008
879. U.S. Competitiveness and Corporate Tax Rates

     March 30, 2008
880. Electronic Arts Chart

     March 23, 2008
881. The Foreign Base Company Sales Income "Manufacturing Exception"

     March 13, 2008
882. Third Circuit Reverses Tax Court in Swallows Holdings

     February 25, 2008
883. Foreign Vacation Homes & Rental Properties

     February 8, 2008
884. Practitioner Cross-Border Activities Can be Costly

     February 6, 2008