You are a resident alien of the United States for tax purposes if you meet either a green card test..

Expats, Tax

On March 5^th, 2019 the IRS released the latest installment of proposed regulations (the “Proposed..

GILTI, Tax

The IRS has released a new Form 1118, “Foreign Tax Credit — Corporations,” and new instructions..

GILTI, Tax, Transition Tax

While regulations were issued on the new Transition Tax (Sec. 965), not much new was provided on..

Tax, Transition Tax

On June 21, 2018, in a highly anticipated decision, the US Supreme Court ruled (essentially) that..

Tax

The Internal Revenue Service issued a news release on Tuesday announcing it will close down the..

FATCA/CRS, Tax

The Tax Cuts and Jobs Act (TCJA) that was enacted on December 22, 2017, includes a deemed..

GILTI, Tax