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Goodbye LIBOR - Hello SOFR/SONIA/SARON/TONA

January 5, 2022

If you have loans, hedges or other financial instruments that use the London Interbank Offered Rate..

Foreign Corporations: Calculating Interest on Over Withholding Refund for US Tax

January 4, 2022

In some instances, foreign corporations may have US withholding tax that is refundable. These..

FATCA Attack: US Passports at Risk For Not Reporting All Foreign Income

November 30, 2021

FATCA (Foreign Account Tax Compliance Act) has enabled the Internal Revenue Service (IRS) to use a..

US Expatriates Paying Foreign Taxes on Investment Income Cannot Take a Credit Against the Net Investment Income Tax

November 22, 2021

US expatriates who are working overseas often become a resident of a foreign country and must pay..

Regulation Deferred Again: Section 987 Recognition and Deferral of Currency Gains/Losses

November 8, 2021

Regulations on the recognition and deferral of currency gains and losses are being deferred for the..

Foreign Trust Reporting Penalties: Is It 5% or 35%?

November 3, 2021

The Internal Revenue Code requires US owners of a foreign trust to ensure it files an annual..

Ready to Defend Your Claim For The Foreign Earned Income Exclusion?

October 28, 2021

Sometimes the Internal Revenue Service (IRS) will challenge a taxpayer’s claim to the foreign..

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