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SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

Aug 26, 2024

In this week’s blog, we discuss a recent Supreme Court decision upholding the constitutionality of the Section 965 transition tax, as well as the impact the decision could have on current filers, particularly those catching up using the Streamlined Procedures.

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Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

May 20, 2024

In this week’s blog, we review the D.C. Circuits Court’s reversal of the Farhy decision, a surprising case from last year holding that the IRS lacks the statutory authority to assess certain international return penalties.

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CORPORATE RESTRUCTURING – A TRAP FOR THE UNWARY EXPAT

Feb 28, 2024

In this week’s blog, we focus on corporate restructurings, which are ripe for misunderstanding and complacency, given that the foreign company rules in the US and in your country of residence can be significantly at odds.

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SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

CORPORATE RESTRUCTURING – A TRAP FOR THE UNWARY EXPAT

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