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Are You a US Citizen Living Outside the US Contemplating Expatriation (or not) – File An Extension Request Today?

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Seeking Clarity in the US Tax Code on behalf of US Taxpayers Everywhere

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Posted in International Tax, Uncategorized

Lessons Learned Preparing & Defending IRS Form 8938 – FATCA

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Foreign Financial Asset Reporting (FATCA) - Form 8938 was enacted March 18, 2010 and requires filing of Form 8938. The FATCA requirement does not replace or otherwise affect a taxpayer’s obligation to file an FinCEN Form 114. Basically if you are a US

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Posted in FATCA, FBAR, Foreign Income, Foreign Investment, International Tax, Tax Treaties

Foreign Earned Income for U.S. Overseas Taxpayers

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Foreign Earned Income for U.S. Overseas Taxpayers. The following was prepared by IRS Employees Bethany Barclay, Technical Specialist LB&I Division & Tracy McFee, CPA Technical Specialist LB&I Division regarding Foreign Earned Income Exclusion (FEIE). Tracy and I met as guest

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Posted in Foreign Income, Foreign Investment, Foreign Tax Credit, International Tax

Foreign Tax Credit (FTC) A Drill Down into IRS Form 1116

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Foreign Tax Credit (FTC) A Drill Down into IRS Form 1116 With all the political rhetoric about borders and boundaries circulating these days by 'news media' outlets the fact of the matter is US Taxpayers are increasingly working and living abroad

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Posted in Alien, Foreign Income, Foreign Investment, Foreign Tax Credit, FTC, International Tax, Tax Credit, Tax Guidance & Preparation

Foreign Earned Income Exclusion (FEIE): Drill Down into IRS Form 2555

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

We get all sorts of fascinating questions from established US Taxpayers as well as those experiencing internationalism for the first time. It seems regardless of the degree of sophistication in US income tax filing obligations most people are out to

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Posted in FATCA, FBAR, Foreign Income, Foreign Investment, International Tax

Top 25 International Tax Questions

Top 25 International Tax Questions

Top 25 International Tax Questions

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Posted in Alien, Foreign Income, Foreign Investment, International Tax

Different Sources of Income Matter FDAP v. ECI

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Different Sources of Income Matter FDAP v. ECI One of the issues difficult for some of my international clients to grasp about the United States is its taxation of citizens and resident aliens alike on their worldwide income without any

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Posted in Alien, Alimony, Distributions, Expatriation, Foreign Income, Foreign Investment, International Tax, Paying Taxes

IRS Form 8833 – Treaty-Based Return Disclosure Under IRC 6114

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

IRS Form 8833 - Treaty-Based Return Disclosure Under IRC 6114 - When MUST It Be Filed? While the light of my life was off at a family wedding in Fargo, ND this past weekend a friend flew into town unexpectedly

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Posted in Foreign Income, Foreign Investment, International Tax, Tax Treaties

Coca Cola’s Recent IRS Statutory Notice of Deficiency – a Tipping Point in International Transfer Pricing Enforcement

In Coca Cola's SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when

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Posted in Foreign Income, Foreign Investment, International Tax, IRS Examination, Tax Abuse, Tax Court, Transfer pricing

Procedures for Requesting Competent Authority Assistance under US Tax Treaties

U.S. competent authority assistance is not necessarily contingent upon whether you sign an agreement with the IRS Examination function contrary to the assertions of some IRS Revenue Agents. Turns out this is important information for some US Taxpayers of international origin

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Posted in China, Competent Authority, International Tax, Israel, Tax Treaties
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