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Tax Court: The IRS Lacks the Power to Collect 5471 Penalties

June 9, 2023

A run of good fortune for U.S. taxpayers with foreign corporate ties continues after the Bittner v...

Beneficial Ownership Information Reporting Finalized

May 24, 2023

On Jan. 17, 2023, the U.S. Treasury Department issued guidance on the type of data input to be..

Royalties Agreements with Companies in Non-Treaty Countries

May 11, 2023

On Nov. 22, 2022, Final 2021 Foreign Tax Credit (FTC) Regulations were issued addressing changes to..

An Under-The-Radar Win Against IRS for Taxpayers

May 2, 2023

Imagine receiving a large gift from your mother by putting the family home in your name or..

Impact of Hungary-U.S. Income Tax Treaty Termination on U.S. Inbound Corporations

April 27, 2023

On July 8, 2022, the Biden Administration announced the termination of the U.S.-Hungary Income Tax..

IRS Updates Foreign Housing Expense Limitations and Residency/Presence Tests

April 4, 2023

In March, the Internal Revenue Service (IRS) released important updates and adjustments regarding..

OECD Guidance on Global Tax Deal Gets a Mixed Reaction

March 20, 2023

On Feb. 2, 2023, the Organization for Economic Co-operation and Development/G20 Inclusive Framework..

A Win for Taxpayers: The Supreme Court Limits Non-Willful FBAR Penalties

March 3, 2023

The long legal journeys for two taxpayers, Ms. Jane Boyd and Mr. Alexandru Bittner, came to a happy..

International and Domestic Cross-Border Tax Residency Issues in the Aftermath of COVID

February 28, 2023

As many companies continue to allow employees to work remotely, working from one’s home or vacation..

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