Every US person with financial interest or signature authority over a foreign financial account(s),..
The substantial presence test is the test used to determine if a nonresident alien (non-US citizen..
Recent changes may eliminate some of the deemed distributions from controlled foreign corporations..
With the IRS finalizing the rules related to the foreign-derived intangible income (FDII) deduction..
Individuals who are US citizens and those who are considered domiciled in the US are subject to US..
The IRS has had a long-standing concern about taxpayers who try to use debt rather than stock..
The IRS has issued Revenue Procedure 2020-17 that provides guidance on exemptions provided to..
If you are a US person who has a direct ownership in a foreign partnership controlled by US persons..
