Very late in 2019, the IRS issued final regulations on the due diligence and reporting requirements..

FATCA/CRS, Tax, Nonresident Alien

If you are a US person who has a direct ownership in a foreign partnership controlled by US persons..

Tax, International Tax

DOES NOT INCLUDE TECHNICAL CORRECTIONS RELIEF FOR THE “DOWNWARD ATTRIBUTION” PROBLEM CREATED BY THE..

GILTI, Tax

The IRS just released additional guidance on virtual currency and how it should be treated for..

Tax

The Internal Revenue Service issued Revenue Procedure 2019-40 and proposed regulations that provide..

GILTI, Tax, Transition Tax

The U.S. officially entered into tax treaty protocols with Japan on August 30. The tax treaty..

Tax

The Internal Revenue Service (IRS) released on September 6 new procedures that will allow certain..

Expats, Tax

After over 30 years from the issuance of Notice 88-22, promised guidance in the form of proposed..

Tax

If you are a resident alien, own more than 10% of the vote or value of a foreign corporation deemed..

Expats, Tax