2012-03-29
Last week the IRS published the following Chief Counsel Advice relating to international taxation.
CCA 201212008: Taxation of Green Card Holders at the Italian Embassy under the 1878 U.S.-Italy consular convention, the 1984 U.S.-Italy income tax treaty, and section 893.
CCA 201212020: Personal liability of the executor of an estate (fiduciary is liable only if it had notice of the claim of the United States before making the distribution). The only asset in the estate was a foreign trust.
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