Links to Blog Posts

1. 2026 Inflation Adjustments for Individuals in the International Tax Arena

   October 12, 2025
2. In the Tax Court & at the IRS Last Month --- September 2025

   October 4, 2025
3. More IRS Treaty Documents

   October 3, 2025
4. Chart of 3M Company v. Commr. (IRS Loses)

   October 2, 2025
5. The "Saving Clause"

   September 25, 2025
6. Chart of AM 2025-002 (BPT Treaty Relief for Rev. Hybrid Entity With US Branch)

   September 21, 2025
7. Semantic Search - Thinking Out Loud

   September 19, 2025
8. In the Tax Court & at the IRS Last Month --- August 2025

   September 19, 2025
9. Times Are A-Changing - TaxProf Blog Is Ending

   September 16, 2025
10. IRS Treaty Documents Are Slowly Improving

    September 15, 2025
11. IRS Publishes Technical Explanations to 1971 Norway Treaty and 1980 Norway Protocol

    September 6, 2025
12. In the Tax Court & at the IRS Last Month --- July 2025

    August 13, 2025
13. Self-Employed Abroad

    August 7, 2025
14. 2025 2nd Quarter Published Expatriates

    July 30, 2025
15. Notes on the OBBB

    July 27, 2025
16. In the Tax Court & at the IRS Last Month --- June 2025

    July 1, 2025
17. Guide to Tax Court Docket Suffixes

    June 30, 2025
18. In the Tax Court & at the IRS Last Month --- May 2025

    June 17, 2025
19. Free Flowchart - Section 2040: Portion of Jointly Owned Property to Include in Gross Estate

    May 27, 2025
20. Hawaiian Philippine Added to Classification of Transactions Chart

    May 24, 2025
21. You Can’t Rely on a Tax Opinion When the Opinion Writer Says It Is Hogwash

    May 16, 2025
22. Elections Related to Foreign Taxes

    May 16, 2025
23. IRS Publishes Technical Explanation to 1974 Polish Treaty

    May 8, 2025
24. In the Tax Court & at the IRS Last Month --- April 2025

    May 7, 2025
25. Tax Court Again Overstates Number of Opinions Issued

    May 3, 2025
26. 2 New IRS Practice Units

    May 2, 2025
27. Famous Tax Quotes - A Multiplier of 54 and Fantastical Numbers

    May 1, 2025
28. 2025 1st Quarter Published Expatriates

    April 23, 2025
29. Famous Tax Quotes - Garden Variety Negligence

    April 19, 2025
30. 6 New IRS Practice Units

    April 17, 2025
31. Famous Tax Quotes - We Can't Just Guess

    April 11, 2025
32. In the Tax Court & at the IRS Last Month --- March 2025

    April 10, 2025
33. 3 New IRS Practice Units

    April 9, 2025
34. IRS Denies Indirect Foreign Tax Credits For Failure to Attach Code §962 Election Statement

    April 8, 2025
35. 2 New IRS Practice Units

    April 4, 2025
36. 5 New IRS Practice Units

    April 2, 2025
37. Number of Chief Counsel Advice Emails

    March 28, 2025
38. In the Tax Court & at the IRS Last Month --- February 2025

    March 26, 2025
39. 8 New IRS Practice Units

    March 25, 2025
40. Tax Court Summary Opinions - Average of 83 Percent of Pro Se Opinions

    March 12, 2025
41. Percentage of Pro Se Opinions in the Tax Court (2001 to 2024)

    March 10, 2025
42. Zip Codes Updated and Enhanced for 2022 Data

    March 4, 2025
43. Filtering of TaxProf Blog Posts

    February 12, 2025
44. Famous Tax Quotes - Nailing Jello to a Wall

    February 10, 2025
45. 2024 IRS Tax Forum PowerPoints

    February 6, 2025
46. In the Tax Court & at the IRS Last Month --- January 2025

    February 4, 2025
47. 2024 Expatriations Increase by 48%

    January 31, 2025
48. Three New FTC Practice Units

    January 30, 2025
49. IRS Tax Exempt Determination Letters Are Not Searchable (They Should Be)

    January 29, 2025
50. In the Tax Court & at the IRS Last Month --- December 2024

    January 28, 2025
51. There Are a Lot of Enrolled Agents in California (Heat Map)

    January 27, 2025
52. Number of Tax Court Opinions Issued By Active Status Judges in 2024

    January 12, 2025
53. Exchange Rates for 2024

    January 9, 2025
54. Supreme & Appellate Court Opinions Cited By the Tax Court in 2024

    January 1, 2025
55. 2025 PLR Fees For 9100 Relief Increase By 15%

    December 29, 2024
56. A Record Number of Pages Published in the Internal Revenue Bulletin for 2024

    December 28, 2024
57. AM 2024-005 - Source of Gain From Certain Dispositions of Stock

    December 21, 2024
58. Review of An IRS-Prepared Form 5471

    December 19, 2024
59. PLR 199914006 - An LLC With 2 Members Was A Disregarded Entity

    December 19, 2024
60. PLR 200923001 (now revoked) - Domestically Controlled REIT

    December 18, 2024
61. PLR 201451009 - Professional Corps Ruled Part Of Affiliated Group

    December 10, 2024
62. IRS Removes Inaccurate Version of the Swedish Treaty

    December 7, 2024
63. Video on Reporting Rules for UK SIPPs

    December 6, 2024
64. Newly Released Treaty Documents

    December 6, 2024
65. In the Tax Court & at the IRS Last Month --- November 2024

    December 4, 2024
66. Lawsky Practice Problems

    December 2, 2024
67. FICA and Self-Employment Tax For Salaries Paid By a Foreign DRE

    November 17, 2024
68. Rev. Rul. 84-79 - Shares Owned Through a Revocable Voting Trust

    November 16, 2024
69. Tax Court Overstates Number of Opinions Issued In Report to Congress (again)

    November 14, 2024
70. Rev. Rul. 77-467 - Redemption With Waiver of Family Attribution & Rental of Real Estate

    November 7, 2024
71. Beneficial Ownership Controls For Consolidated Returns (Miami National Bank)

    November 6, 2024
72. More on Classifying Transactions

    November 5, 2024
73. Famous Tax Quotes - Rococo Fugue & Baroque Fugue

    November 3, 2024
74. In the Tax Court & at the IRS Last Month --- October 2024

    November 2, 2024
75. 2024 3rd Quarter Published Expatriates - Highest In 4 Years

    October 28, 2024
76. Distribution of Own Debt As a Dividend (Kraft Foods)

    October 27, 2024
77. Famous Tax Quotes - Five "Any's" In One Sentence

    October 23, 2024
78. 2025 Inflation Adjustments for Individuals in the International Tax Arena

    October 22, 2024
79. Rev. Rul. 75-512 - Redemption Not Equivalent to a Dividend Under 302(b)(1)

    October 20, 2024
80. Rev. Rul. 70-469 - Nominal Ownership - Affiliated Group Definition

    October 19, 2024
81. Passive Income For Less Than 10% Limited Partner (Chart)

    October 13, 2024
82. In the Tax Court & at the IRS Last Month --- September 2024

    October 4, 2024
83. Rev. Rul. 76-19 - Canadian Corp With Employees In the U.S.

    October 1, 2024
84. CFC Overlap Rule to Avoid PFIC Classification (PLR 200943004 & Reg. 1.958-1(d))

    September 30, 2024
85. Famous Tax Quotes - A Slender Reed

    September 27, 2024
86. Captive Insurance Companies Can Have A Disastrous Tax Result (CCA 202422010)

    September 23, 2024
87. Enrolled Agents By Country (September 2024)

    September 21, 2024
88. "Principals" as Partners in a Partnership

    September 16, 2024
89. No 245A DRD for Dividends from a SFC to a CFC

    September 12, 2024
90. In the Tax Court & at the IRS Last Month --- August 2024

    September 1, 2024
91. Where Is the GILTI High-Tax Exception?

    August 30, 2024
92. In the Tax Court & at the IRS Last Month --- July 2024

    August 21, 2024
93. Update to Chart - Classification of Transactions

    August 15, 2024
94. 2024 2nd Quarter Published Expatriates

    July 31, 2024
95. New Resource Page - Certain High Thresholds

    July 25, 2024
96. Famous Tax Quotes - Does Not Pass the Smell Test

    July 16, 2024
97. In the Tax Court & at the IRS Last Month --- June 2024

    July 5, 2024
98. Famous Tax Quotes - Shoebox Method

    June 10, 2024
99. In the Tax Court & at the IRS Last Month --- May 2024

    June 2, 2024
100. Deciphering Tax Court Opinion Release Patterns

     May 30, 2024
101. Four New Charts

     May 26, 2024
102. In the Tax Court & at the IRS Last Month --- April 2024

     May 16, 2024
103. 2024 1st Quarter Published Expatriates

     May 1, 2024
104. Chart for the Tax Court Case of PICCIRC, LLC --- Disguised Sale & Partnership Shams

     April 23, 2024
105. Famous Tax Quotes - The Proof of the Pudding is in the Eating

     April 21, 2024
106. In the Tax Court & at the IRS Last Month --- March 2024

     April 1, 2024
107. Section 911 Housing Cost Amounts Updated for 2024

     March 21, 2024
108. In the Tax Court Last Month --- February 2024

     March 6, 2024
109. Enrolled Agents Per Million People By State

     March 3, 2024
110. Enrolled Agents By Country (September 2023)

     February 25, 2024
111. Famous Tax Quotes - A Conjurer’s Circle

     February 20, 2024
112. Famous Tax Quotes - Must Timely File Using The Best Information Available

     February 11, 2024
113. Famous Tax Quotes - Insurance Premiums Were Nonsense

     February 4, 2024
114. Tax Court Statistics - 2023

     January 27, 2024
115. 2023 4th Quarter Published Expatriates

     January 26, 2024
116. Exchange Rates for 2023

     January 9, 2024
117. Pages Published by the IRS in 2023 (in the Federal Register & in the IRB)

     January 8, 2024
118. IRS Written Determinations Increased By 4% In 2023

     January 2, 2024
119. 2024 PLR Fees For 9100 Relief Remain the Same

     December 30, 2023
120. Videos Published in 2023

     December 27, 2023
121. Situational Charts Published in 2023

     December 22, 2023
122. Famous Tax Quotes - A Bundle of Sticks

     December 17, 2023
123. Top 8 Appellate Court Cases Cited by the Tax Court

     December 11, 2023
124. Top 10 Supreme Court Cases Cited by the Tax Court

     December 4, 2023
125. New IRS Practice Unit - Taxation of Beneficiary of a Foreign Non-Grantor Trust

     December 1, 2023
126. Famous Tax Quotes - Tweedledum and Tweedledee

     November 19, 2023
127. Famous Tax Quotes - Congress Does Not Hide Elephants In Mouseholes

     November 18, 2023
128. Regular Expressions in the Tax World

     November 10, 2023
129. 2024 Inflation Adjustments for Individuals in the International Tax Arena

     November 9, 2023
130. 2023 3rd Quarter Published Expatriates

     October 27, 2023
131. Famous Tax Quotes - Hard To See Duress Without Any IRS Interaction

     October 15, 2023
132. Tax Court Judge Lauber Is a Rock Star

     September 20, 2023
133. New situational charts published today

     September 11, 2023
134. Tax Case Quizzes

     September 5, 2023
135. 2023 2nd Quarter Published Expatriates

     July 20, 2023
136. New IRS Practice Unit: Expatriation – Mark-to-Market Tax Regime

     July 13, 2023
137. New IRS Practice Unit - FTC - Categorization of Income and Taxes Into Proper Basket

     June 27, 2023
138. Zip Codes Updated for 2020 Data

     June 3, 2023
139. Famous Tax Quotes - Confusing the Terms “Petitioner” and “Respondent”

     May 19, 2023
140. Three New IRS Practice Units - 267(a)(3), 385, and 163(j) for CFCs

     May 18, 2023
141. Treaty Updates Page

     May 15, 2023
142. Famous Tax Quotes - Bargaining For Tax Benefits

     April 19, 2023
143. 2023 1st Quarter Published Expatriates

     April 18, 2023
144. Famous Tax Quotes - Tax Laws Should Be Intelligible

     April 4, 2023
145. The IRS Publishes Far Fewer PLRs Than It Used To

     March 31, 2023
146. 4,000 Tax Cases and Rulings

     March 27, 2023
147. 3 New Videos – PFIC With No QEF, Pedigreed QEF, & Unpedigreed QEF

     March 21, 2023
148. Famous Tax Quotes - The Most Honorable People I Have Ever Dealt With

     March 18, 2023
149. Section 911 Housing Cost Amounts Updated for 2023

     March 16, 2023
150. Famous Tax Quotes - Self-serving, Unreliable, Unverified, and Contradicted Testimony

     March 11, 2023
151. Musings on Structure Planning For Closely-Held Foreign Entities

     March 6, 2023
152. Famous Tax Quotes - “To tautologize, section 741 applies only where it applies”

     February 17, 2023
153. IRS Regulations Lowest in 24 Years

     February 13, 2023
154. Charts Created in 2022

     February 11, 2023
155. 2022 Published Expatriates Increases By 57%

     January 26, 2023
156. Exchange Rates for 2022

     January 25, 2023
157. A Tangled Web of Definitions

     January 4, 2023
158. ChatGPT – Fun, But Not Yet Serious for Legal Writing

     December 7, 2022
159. Property of Former US Residents: Owning Stock Through a Partnership

     December 2, 2022
160. Recent Regulation Packages Related To International Tax

     October 29, 2022
161. 2022 3rd Quarter Published Expatriates

     October 25, 2022
162. 2023 Inflation Adjustments for Individuals in the International Tax Arena

     October 20, 2022
163. New IRS Practice Unit – FBAR (FinCEN Form 114)

     October 19, 2022
164. How inaccurate is the IRS Version of the Sweden Treaty (pretty inaccurate)

     September 23, 2022
165. Reviewing Form 5471

     September 9, 2022
166. 16 New Charts Published

     August 30, 2022
167. New IRS Practice Unit - IRC 958 Rules for Determining Stock Ownership

     August 30, 2022
168. 13,000 Regulation Examples

     August 16, 2022
169. Famous Tax Quotes - One Cannot Distribute What One Does Not Have

     July 28, 2022
170. 2022 2nd Quarter Published Expatriates

     July 27, 2022
171. New IRS Practice Unit - 1120-F Delinquent Returns - Filing Deadline Waiver Process

     July 26, 2022
172. Famous Tax Quotes - Tax Legislation Is Not A Promise

     July 25, 2022
173. Internet Birthday --- June 26, 2005

     June 26, 2022
174. Famous Tax Quotes - Turning Square Corners

     June 5, 2022
175. Recent Web Traffic Data

     May 9, 2022
176. 2022 1st Quarter Published Expatriates

     April 25, 2022
177. New IRS Practice Unit - NRA Deferred Compensation

     April 2, 2022
178. New situational chart and video on Income Classification

     March 29, 2022
179. Famous Tax Quotes - Congress Did Not Want To Deal With Citizens As If They Were Still In The Nursery

     March 18, 2022
180. Section 911 Housing Cost Amounts Updated for 2022

     March 9, 2022
181. Update to Zip Codes App and New Heat Maps

     February 24, 2022
182. 2021 Published Expatriates Decreases By 64%

     January 25, 2022
183. 8 New Charts Published

     January 20, 2022
184. New Flowchart – Section 1202 Exclusion for Qualified Small Business Stock (“QSBS”)

     January 18, 2022
185. Five New IRS Practice Units

     December 15, 2021
186. New Form 5471, Schedule J Video

     December 3, 2021
187. 2022 Inflation Adjustments for Individuals in the International Tax Arena

     November 16, 2021
188. 2021 3rd Quarter Published Expatriates

     November 12, 2021
189. Two New IRS Practice Units - NRA employee expenses & Form 1040NR for RGS

     October 31, 2021
190. Capitalization Trivia

     September 17, 2021
191. 14 New Charts Published

     September 10, 2021
192. New IRS Practice Unit - FTC (Business) General Principles

     September 2, 2021
193. 2 New IRS Practice Units

     August 26, 2021
194. Two New Heat Maps – AGI by State & Number of Dependents by State

     August 19, 2021
195. Famous Tax Quotes - Taxes Are What We Pay For Civilized Society

     August 14, 2021
196. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     August 4, 2021
197. New IRS Practice Unit: Overview of IRC 987 and Branch Operations in a Foreign Currency

     August 4, 2021
198. 2021 2nd Quarter Published Expatriates

     July 28, 2021
199. IRS Data By Zip Code (Using Python and Flask)

     July 20, 2021
200. 3 New IRS Practice Units

     July 9, 2021
201. New IRS Practice Unit: Concepts of GILTI

     June 18, 2021
202. 13 New Charts Published

     June 15, 2021
203. 130 New Tax Charts – LOB Active Trade or Business Test – Derived In Connection With

     June 8, 2021
204. New IRS Practice Unit: Allocation and Apportionment of Deductions

     May 21, 2021
205. Famous Tax Quotes - A Detour to Crazy Town

     May 17, 2021
206. 2021 1st Quarter Published Expatriates

     April 28, 2021
207. Famous Tax Quotes - Two-Way Street: Downhill for the IRS & Uphill for the Taxpayer

     April 27, 2021
208. New IRS Practice Units - FTC Carryback and Carryover & Liquidating Distributions of a Partner’s Interest in a Partnership

     April 12, 2021
209. US Treaty Limitation on Benefits Status Map

     April 9, 2021
210. AM 2021-002 – Relevance & Check-the-Box Elections

     April 3, 2021
211. Flow-Thru Symbols: An Up-Side-Down “Funnel” Theme

     April 1, 2021
212. Multiple new situational charts published

     April 1, 2021
213. New IRS Practice Unit: 965 Transition Tax

     March 24, 2021
214. Section 911 Housing Cost Amounts Updated for 2021

     March 2, 2021
215. Famous Tax Quotes - Death May Escape the Woes of Life . . .

     February 20, 2021
216. 2020 Sets New Record For Published Expatriates

     February 3, 2021
217. A Brief History of U.S. Tax Expatriation Rules

     January 15, 2021
218. U.K. Pension Lump-Sum Distributions

     November 8, 2020
219. 7 New Tax Charts Published

     November 6, 2020
220. 2021 Inflation Adjustments for Individuals in the International Tax Arena

     November 6, 2020
221. IRS Delinquent International Information Return Submission Procedures Have Been Updated

     November 6, 2020
222. Famous Tax Quotes - Memory Dulled by a Penitentiary Term Served

     November 3, 2020
223. 2020 Third Quarter Published Expatriates – 2020 Is Already the Highest Year Ever

     October 28, 2020
224. Famous Tax Quotes - Fictional Corporate Camouflage

     October 25, 2020
225. 88% of Expatriates Have a Net Worth of Less than $2 Million

     October 18, 2020
226. FBAR Reporting For Indirectly Owned Foreign Bank Accounts

     September 14, 2020
227. A Tax Attorney Uses Python

     September 1, 2020
228. New IRS Practice Unit: Foreign Earned Income

     August 27, 2020
229. 2020 Second Quarter Published Expatriates – Second Highest Quarterly Number Ever

     August 13, 2020
230. U.S. Partnerships Owning CFCs

     August 4, 2020
231. Famous Tax Quotes - No Rational Person . . .

     July 29, 2020
232. Famous Tax Quotes - Backdating of Documents

     July 28, 2020
233. New IRS Practice Units: Reasonable Cause and Good Faith & FTC Limitation

     July 18, 2020
234. Average Price of U.S. Real Estate Sold -- By Country

     July 3, 2020
235. Famous Tax Quotes - Born in Generosity; Debauched in Avarice

     June 30, 2020
236. 5 New Tax Charts Published

     June 17, 2020
237. Free Flowchart - Section 894(c): Hybrid & Reverse Hybrid Entities

     June 9, 2020
238. New IRS Practice Unit: Flow-Through Entities Effects on FTC

     June 4, 2020
239. Two New (& One Updated) IRS Practice Units

     May 9, 2020
240. 2020 First Quarter Published Expatriates –Highest Quarterly Number Ever

     May 7, 2020
241. Three New IRS Practice Units

     April 29, 2020
242. New IRS Practice Unit On The Statute Of Limitations

     April 11, 2020
243. New IRS Practice Unit for “Adjustments for Overwithholding on Form 1042”

     April 8, 2020
244. Rev. Proc. 2020-17 - Exemption From Filing Forms 3520 and 3520-A for Applicable Tax-Favored Foreign Trusts

     March 3, 2020
245. Section 911 Housing Cost Amounts Updated for 2020

     February 25, 2020
246. 11 New Tax Charts

     February 15, 2020
247. 2019 Published Expatriates - Lowest Level in Six Years

     February 10, 2020
248. New IRS Practice Unit – FDAP Statistical Sampling in the Audit of a U.S. Withholding Agent

     January 23, 2020
249. Video - Downward Attribution Form 5471

     January 9, 2020
250. Form 8993 With Graphic of Formulas

     December 26, 2019
251. Famous Tax Quotes - Perhaps Congress Just Stubbed Its Toe

     December 17, 2019
252. Video - Sec. 1446(f) Withholding on Sales of Partnerships Engaged in US Business

     December 12, 2019
253. Famous Tax Quotes - Penalties For Hardheaded Persistence

     December 5, 2019
254. Famous Tax Quotes - Like white asparagus or a blood orange

     December 3, 2019
255. 2020 Inflation Adjustments for Individuals in the International Tax Arena

     November 18, 2019
256. 2019 3rd Quarter Published Expatriates - Lowest Since 4th Quarter 2012

     November 8, 2019
257. Famous Tax Quotes - The Regulations Barely Rocked The Statutory Boat

     October 24, 2019
258. 8 New Charts Of Examples Regarding Classification of Cloud Transactions & Computer Programs

     September 26, 2019
259. 2019 2nd Quarter Published Expatriates

     August 14, 2019
260. Famous Tax Quotes - Forming HoldCo To Acquire Target Is Not Unusual

     August 7, 2019
261. Famous Tax Quotes - A taxpayer’s own documents

     August 4, 2019
262. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 5, 2019
263. 2019 1st Quarter Published Expatriates - 1,019 Names

     May 10, 2019
264. Section 911 Housing Cost Amounts Updated for 2019

     April 17, 2019
265. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2018)

     April 17, 2019
266. New IRS Practice Units published in March

     March 18, 2019
267. 2018 4th Quarter Published Expatriates - A total of 685

     March 12, 2019
268. GILTI Deduction Allowed With 962 Election (Proposed Regulations)

     March 5, 2019
269. Eaton Corp. v. Commr., 152 T.C. No. 2 (2019)

     March 1, 2019
270. New IRS Practice Unit: Creation of a Permanent Establishment (PE) through the Activities of a Dependent Agent in the United States

     January 31, 2019
271. Rental of Real Estate to Yourself

     January 23, 2019
272. Form 5472 Failure to File Penalty Increased to $25,000

     January 14, 2019
273. The “Certification” on Form W-8BEN For Royalties

     January 7, 2019
274. The “Certification” on Form W-8BEN For Interest

     December 31, 2018
275. The “Certification” on Form W-8BEN For Dividends

     December 24, 2018
276. The “Certification” on Form W-8BEN For Services

     December 17, 2018
277. 2019 Inflation Adjustments for Individuals in the International Tax Arena

     November 20, 2018
278. 2018 Third Quarter Published Expatriates – A Total of 1,107

     November 16, 2018
279. New & Updated Draft International Forms

     October 19, 2018
280. Video - GILTI for a CFC With & Without Debt

     October 19, 2018
281. 12 New Tax Charts

     October 18, 2018
282. Famous Tax Quotes - New Batboy Changing the Outcome of the World Series

     October 4, 2018
283. Famous Tax Quotes - That’s How The Cookie Crumbles

     September 22, 2018
284. Video – GILTI in a Minute

     September 17, 2018
285. GILTI Regulations Preamble: Is a 100 Word Sentence Too Long?

     September 13, 2018
286. 13 Charts of Code §958 Regulation Examples

     August 28, 2018
287. 8 Charts of Sec. 965 Transition Tax Regulation Examples

     August 9, 2018
288. 2018 Second Quarter Published Expatriates – A Total of 1,090

     July 31, 2018
289. IRS 2015 Statistics on Form 8805 (Inbound Partnership Investing)

     June 29, 2018
290. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 28, 2018
291. 8 New Tax Charts

     June 28, 2018
292. Famous Tax Quotes - IRS To Enforce Tax Laws; Not To Maximize Tax Receipts

     May 22, 2018
293. 2018 First Quarter Published Expatriates – A Total of 1,099

     May 7, 2018
294. IRS Publication on New Section 965 Transition Tax

     April 14, 2018
295. Famous Tax Quotes - “One Big Wallet”

     April 14, 2018
296. New Video – Attribution Rules for 965 Specified Foreign Corporations

     April 6, 2018
297. Video on IRS FAQs on Section 965 Transition Tax Reporting

     March 20, 2018
298. Video - Form 5471 Attribution from NRA Spouses

     March 9, 2018
299. Qualified Electing Funds (“QEFs”) Receiving Qualified Dividend Income

     March 1, 2018
300. Code §965: Individuals Recognizing the Deemed Repatriation in 2017 vs. 2018

     February 14, 2018
301. Update to Video: Global Intangible Low-taxed Income (“GILTI”)

     February 10, 2018
302. 2017 Fourth Quarter Published Expatriates – First Annual Decrease in Five Years

     February 8, 2018
303. Andrew Mitchel Speaking on "GILTI" at IFA regional meeting

     February 2, 2018
304. New Video: Form 2555 and the Foreign Earned Income Exclusion

     February 1, 2018
305. TCJA Explanatory Video: Global Intangible Low-taxed Income (“GILTI”)

     January 2, 2018
306. Tax Cuts and Jobs Act Explanatory Video: Code §965 Deemed Repatriation from Foreign Corporations

     December 21, 2017
307. New Flowchart – Form 5471 Filing Requirements

     November 13, 2017
308. 2017 Third Quarter Published Expatriates – A Total of 1,376

     November 1, 2017
309. 2018 Inflation Adjustments for Individuals in the International Tax Arena

     October 20, 2017
310. 5 New Tax Charts

     October 20, 2017
311. Famous Tax Quotes - Plodding Through A Tax Court Opinion

     September 24, 2017
312. Famous Tax Quotes - Almost Indistinguishable Lines

     September 18, 2017
313. Withdrawal of Prior Blog Post Regarding Australian Superannuation Funds

     September 14, 2017
314. 5 New Tax Charts

     September 6, 2017
315. Famous Tax Quotes - Anticlimactic Discoveries

     August 24, 2017
316. 5 New Tax Charts

     August 10, 2017
317. Belize IBC Selling Through Amazon FBA

     August 4, 2017
318. 2017 Second Quarter Published Expatriates – Second Highest Ever

     August 2, 2017
319. Tax Court Declines to Follow Rev. Rul. 91-32

     July 20, 2017
320. Famous Tax Quotes - An Unsubstantiated Presumption

     July 6, 2017
321. 5 New Tax Charts

     July 1, 2017
322. Failures to Adjust for Inflation

     June 21, 2017
323. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 11, 2017
324. Famous Tax Quotes - Careful / Close / Extra / Heightened / Rigid / Special / Strict Scrutiny For Related Party Transactions

     June 9, 2017
325. 5 New Tax Charts

     June 2, 2017
326. 5 New Tax Charts

     May 12, 2017
327. 2017 First Quarter Published Expatriates – A Total of 1,313

     May 9, 2017
328. Famous Tax Quotes - Blind Guesses Are Not Good Faith Estimates

     March 30, 2017
329. Famous Tax Quotes - Lower Court Overruling a Higher Court

     March 28, 2017
330. Section 911 Housing Cost Amounts Updated for 2017

     March 24, 2017
331. New Form 5472 Filing Requirements for Foreign-Owned U.S. Disregarded Entities (“FOUSDEs”)

     March 6, 2017
332. Being Engaged in U.S. Business Through Independent Agents

     February 27, 2017
333. Famous Tax Quotes - Caligula & Taxes

     February 20, 2017
334. 2016 Fourth Quarter Published Expatriates – New Annual Record

     February 8, 2017
335. 15 New Tax Charts

     February 6, 2017
336. Form 8886: Section 988 Losses >50k Can Be Reportable Transactions

     February 1, 2017
337. Famous Tax Quotes - Congress Does Not Legislate in Logic Puzzles

     January 27, 2017
338. Update to Form 8833 Flowchart (Treaty-Based Return Positions)

     January 27, 2017
339. Free Flowchart – Reg 301.7701-7: Trusts -- Domestic and Foreign

     January 26, 2017
340. Free Flowchart – Reg 301.6114-1 Disclosure of Treaty-Based Return Positions (Form 8833)

     January 23, 2017
341. Increases in Private Letter Ruling Fees for 2017

     January 12, 2017
342. PFIC Mark-to-Market Election Charts & Videos

     January 10, 2017
343. The “Sailing Permit”

     December 28, 2016
344. Final Code §987 Regulations!!

     December 26, 2016
345. 23 New Charts - Code §956 Regulation Examples from T.D. 9792

     December 15, 2016
346. Tax Return Preparation Automation

     December 2, 2016
347. New Videos November 2016

     November 30, 2016
348. 11 New Charts of Foreign Trust Distributions Through Intermediaries

     November 17, 2016
349. 2016 Third Quarter Published Expatriates – Second Highest Ever

     November 9, 2016
350. New Videos - October 2016

     October 31, 2016
351. 2017 Inflation Adjustments for Individuals in the International Tax Arena

     October 27, 2016
352. Over 50 New Situational Charts – Code §7874 Regulation Examples

     October 22, 2016
353. Famous Tax Quotes - Source of Income When Business Is Begun In One Country And Ended In Another

     October 19, 2016
354. New Videos - September 2016

     September 30, 2016
355. New Videos - August 2016

     September 13, 2016
356. Famous Tax Quotes - Clapping With One Hand

     August 26, 2016
357. Free Flowchart – Reg. 1.937-1 – Bona Fide Residency in a U.S. Possession

     August 25, 2016
358. Famous Tax Quotes - King Minos’ Labyrinth

     August 3, 2016
359. New Videos - July 2016

     July 29, 2016
360. 2016 Second Quarter Published Expatriates

     July 28, 2016
361. Substantiation of Deductions to Foreign Contractors

     July 22, 2016
362. New Videos - June 2016

     June 30, 2016
363. Free Flowchart - Form 5472 Filing Requirements (Code §§6038A and 6038C)

     June 7, 2016
364. New Videos - May 2016

     May 31, 2016
365. Famous Tax Quotes - “Tax Language”

     May 19, 2016
366. Tax Treaty Limitation on Benefits (“LOB”) & Form W8-BEN-E

     May 10, 2016
367. Over 1,000 Published Expatriates in 2016 Q1 - The New Normal

     May 4, 2016
368. New Videos - April 2016

     April 29, 2016
369. Encouraging Foreign Investment - A Distorted U.S. Tax Policy

     April 3, 2016
370. New Videos - March 2016

     March 31, 2016
371. Section 911 Housing Cost Amounts Updated for 2016

     March 22, 2016
372. Rev. Rul. 2016-8: Tax Aspects of the Cuban Thaw

     March 10, 2016
373. New Videos - February 2016

     March 1, 2016
374. Charts of Examples in Rev. Proc. 91-55: Form 5472 & Direct and Ultimate Indirect 25% Shareholders

     February 22, 2016
375. New Expatriate Record for 2015 – Nearly 4,300 Expatriations

     February 5, 2016
376. Famous Tax Quotes - Where to Draw the Line

     January 29, 2016
377. Sale of Stock of a CFC – Example of the Potential Benefit of Code §1248(b)

     January 26, 2016
378. Rev. Rul. 56-613 Video (Failed B Reorg - Indirect Control)

     January 24, 2016
379. Flowchart - Section 267(a)(2) & (3) Related Party Matching Rules

     December 22, 2015
380. FAST Act Passport Revocation Provisions

     December 11, 2015
381. The Escalation of Offshore Penalties Over the Last 20 Years

     November 2, 2015
382. 2015 Third Quarter Published Expatriates – A Record High

     October 26, 2015
383. 2016 Inflation Adjustments for Individuals in the International Tax Arena

     October 23, 2015
384. FATCA Overview - Crawford v. U.S. Dep't of the Treasury

     October 17, 2015
385. Famous Tax Quotes - The Basic Structure of the Internal Revenue Code

     October 5, 2015
386. Is the IRS Missing Names From Its Quarterly Publication of Expatriates?

     September 16, 2015
387. Chart of Rev. Rul. 84-125 - Accrual of Foreign Tax Credit on Contested Liability & 10 Year Limitations Period

     September 7, 2015
388. Charts of 704(c) Traditional Method & Trad. Meth. With Curative Allocations

     September 5, 2015
389. Charts of Examples in Code §6038A Regulations: Form 5472 Reporting Requirements

     August 25, 2015
390. Flowchart - PFIC Mark-to-Market Elections

     August 20, 2015
391. Recent Publications

     August 14, 2015
392. New FBAR Due Date

     August 12, 2015
393. 2015 - 2016 IRS Priority Guidance Plan - International Issues

     August 11, 2015
394. 2015 Second Quarter Published Expatriates – Lowest in Years

     July 30, 2015
395. Video: U.S. Taxation of Foreign Vacation Homes Held Thru Entities

     June 29, 2015
396. Application of PFIC Look-Through Rules to Foreign Corporation with U.S. Subsidiaries

     June 18, 2015
397. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 9, 2015
398. When an Active NFFE Can Be a Passive NFFE

     June 3, 2015
399. Charts of Rev. Rul. 2015-09 & Rev. Rul. 2015-10

     May 11, 2015
400. The Exodus Continues (2015 1st Quarter Published Expatriates)

     May 7, 2015
401. Recognition of Losses on Dispositions of PFICs

     April 14, 2015
402. Famous Tax Quotes - Muddled Tax Return Reporting

     April 2, 2015
403. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2014)

     March 27, 2015
404. JCT Excellent Summary of U.S. Cross-Border Tax Rules

     March 18, 2015
405. 2014 - More Expatriations Than Ever

     February 10, 2015
406. New Private Letter Ruling Fees

     February 5, 2015
407. Charts of Examples in Notice 2014-52

     February 5, 2015
408. A Reminder for Green Card Holders Living Outside the U.S.

     January 3, 2015
409. Famous Tax Quotes - Residence - As Many Colors As Joseph's Coat

     January 1, 2015
410. McLaulin – Failed Spin-Off (Situational Chart)

     December 29, 2014
411. IRS International Practice Units

     December 23, 2014
412. Video: Tax as a Percentage of GDP: 1965 to 2013

     December 17, 2014
413. Famous Tax Quotes - A Rose is a Rose is a . . .

     December 13, 2014
414. Chart of PLR With Outbound 332 Liquidation

     December 7, 2014
415. Why U.S. Companies Invert Video

     December 3, 2014
416. International PLRs of Note for the 46th and 47th week of 2014

     December 2, 2014
417. Willful vs. Non-Willful FBAR Violations

     November 22, 2014
418. IRS Documents Released Under Freedom of Information Act

     November 20, 2014
419. New Rules for Canadian RRSPs & RRIFs

     November 2, 2014
420. 2015 Inflation Adjustments for Individuals in the International Tax Arena

     November 2, 2014
421. 2014 Third Quarter Published Expatriates – Third Highest Ever

     October 24, 2014
422. Famous Tax Quotes - Taxing Citizens by Reason of Citizenship

     October 3, 2014
423. Famous Tax Quotes - "Maxims" & "Minims"

     September 28, 2014
424. Payments to Foreign Contractor Entities: Form W-8BEN-E

     September 22, 2014
425. International PLRs of Note for the 38th week of 2014

     September 22, 2014
426. Famous Tax Quotes - “Laughable” Test - All Caps Spelling

     September 10, 2014
427. International PLRs of Note for the 36th week of 2014

     September 5, 2014
428. International PLRs of Note for the 34th week of 2014

     August 22, 2014
429. Chart of PLR 201432002: No Inversion as a Result of an F Reorganization & an IPO

     August 19, 2014
430. Famous Tax Quotes - From the Brow of Zeus

     August 15, 2014
431. International PLRs of Note for the 32nd week of 2014

     August 14, 2014
432. 2014 Second Quarter Published Expatriates

     August 6, 2014
433. Charts of Examples in Notice 2014-44

     July 28, 2014
434. Past IRS Memoranda on the Singapore Central Provident Fund

     July 4, 2014
435. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 13, 2014
436. Chart of CCA 201420017: Code §956: Funneling of Loan through One CFC Partner is Disregarded

     May 20, 2014
437. 2014 First Quarter Published Expatriates - Second Highest Ever

     May 1, 2014
438. Section 911 Housing Cost Amounts Updated for 2014

     April 15, 2014
439. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2013)

     March 27, 2014
440. Chart of PLR 201411006 - Combination of Two Consolidated Groups Owned by Foreign Parent

     March 18, 2014
441. International PLRs for the 10th week of 2014

     March 13, 2014
442. Chart of Central de Gas de Chihuahua

     February 22, 2014
443. International PLRs for the 7th and 8th week of 2014

     February 22, 2014
444. Famous Tax Quotes - Can’t Have Your Cake and Eat It Too

     February 22, 2014
445. Famous Tax Quotes - Hiding the Pea

     February 20, 2014
446. Statute of Limitations for Foreign-Related Items

     February 18, 2014
447. Famous Tax Quotes - Expatriation is a Serious Act

     February 16, 2014
448. Charts of Examples in §1361 Regulations: Termination of QSub Elections

     February 14, 2014
449. Quarterly List of Expatriates: Source of Data

     February 12, 2014
450. 2013 Expatriations Increase by 221%

     February 6, 2014
451. FBAR Video

     February 5, 2014
452. International PLRs for the 5th week of 2014

     February 5, 2014
453. International PLRs for the 4th week of 2014

     January 27, 2014
454. Charts of Examples in §355 Regulations: Continuity of Interest

     January 24, 2014
455. Charts of Examples in New PFIC Annual Filing Requirement Regulations (Form 8621)

     January 15, 2014
456. International PLRs for the 2nd week of 2014

     January 12, 2014
457. New Free Flowchart at Tax-Charts.com : Code §357 Assumption of Liabilities in Certain Exchanges

     January 9, 2014
458. New Rules for PFIC Annual Filing (Form 8621)

     January 8, 2014
459. International PLRs for the 1st week of 2014

     January 3, 2014
460. International PLRs for the 52nd week of 2013

     December 31, 2013
461. Free Simplified Section 351 Exchange Flowchart

     December 26, 2013
462. International PLRs for the 51st week of 2013

     December 20, 2013
463. Change to Weekly PLR Posts

     December 19, 2013
464. Famous Tax Quotes - Morass of United States Tax Laws

     December 17, 2013
465. International PLRs for the 50th week of 2013

     December 16, 2013
466. Famous Tax Quotes - Earnings and Profits

     December 15, 2013
467. Dover - Check-the-Box and Sale Video

     December 8, 2013
468. Form 5471, Schedule J Video

     December 7, 2013
469. International PLRs for the 49th week of 2013

     December 6, 2013
470. New Resource Page: Monetary Penalties for Failure to File Common U.S. International Tax Forms

     December 4, 2013
471. Chart of Rev. Rul. 66-79 - Deductibility of Contributions to "Foreign Feeder" Charity

     December 2, 2013
472. Famous Tax Quotes - Precedent

     December 1, 2013
473. International PLRs for the 48th week of 2013

     November 29, 2013
474. Chart of Rev. Rul. 63-252 - Deductibility of Contributions to "Foreign Feeder" Charities

     November 27, 2013
475. New Addition to the Blog: Resource Pages

     November 26, 2013
476. International PLRs for the 47th week of 2013

     November 22, 2013
477. International PLRs for the 46th week of 2013

     November 22, 2013
478. Chart of Rev. Rul. 71-336 - Corporation as Conduit for Exchange of Stock a Taxable Transaction

     November 16, 2013
479. International PLRs for the 45th week of 2013

     November 15, 2013
480. Famous Tax Quotes - If Rube Goldberg Had Been a Tax Accountant

     November 15, 2013
481. 2013 Third Quarter Published Expatriates

     November 13, 2013
482. Chart of Rev. Rul. 67-192 - Section 367 Triggers Gain, but not Loss, in Outbound 351 Transaction

     November 12, 2013
483. Chart of Chief Counsel Advice AM2013-006: §302 Redemption Reduces CFC's Pool of Foreign Income Taxes

     November 9, 2013
484. International PLRs for the 44th week of 2013

     November 8, 2013
485. Chart of Rev. Rul. 70-253 - Payment of Compensation to Partnership Employee Deductible by Partner under §162(a)

     November 5, 2013
486. 2014 Inflation Adjustments for Individuals in the International Tax Arena

     November 4, 2013
487. Chart of Rev. Rul. 66-365 - Solely for Voting Stock: Cash in Lieu of Fractional Shares

     November 4, 2013
488. International PLRs for the 43rd week of 2013

     November 2, 2013
489. International PLRs for the 42nd week of 2013

     November 2, 2013
490. International PLRs for the 41st week of 2013

     October 31, 2013
491. Chart of PLR 201340010 - Manufacturing Exception to FBCSI - Growing Activities can be Production Activities

     October 23, 2013
492. International PLRs for the 40th week of 2013

     October 23, 2013
493. Famous Tax Quotes - The Form of a Transaction Can Control Tax Consequences

     October 22, 2013
494. Famous Tax Quotes - The IRM Holds No Legal Significance

     October 11, 2013
495. Chart of PLR 201324005 - ADS Not Required for Possession Located Property Held Through Partnership

     October 2, 2013
496. International PLRs for the 39th week of 2013

     September 27, 2013
497. Chart of Rev. Rul. 90-76 - Foreign Corporations: Liquidating Distributions of USRPIs

     September 26, 2013
498. Chart of PLR 201328003 - Deemed Distribution and Contribution with Circular Flow of Cash

     September 25, 2013
499. International PLRs for the 38th week of 2013

     September 23, 2013
500. Famous Tax Quotes - [Un]Comfortable Degree of Accuracy

     September 22, 2013
501. New Attorney Announcement - Ryan E. Dunn

     September 20, 2013
502. Situational Chart of Rev. Rul. 89-103 - Stapling of Interests Triggers Inbound "F" Reorganization

     September 17, 2013
503. International PLRs for the 37th week of 2013

     September 13, 2013
504. Situational Chart of Rev. Rul. 58-422 - Merger an "F" Reorg & Two 332 Liquidations

     September 13, 2013
505. Situational Chart of Rev. Rul. 70-434 - Spin-Off & "B" Reorganization

     September 11, 2013
506. Situational Charts of "F" Reorganizations of "S" Corporations

     September 9, 2013
507. International PLRs for the 36th week of 2013

     September 6, 2013
508. International PLRs for the 35th week of 2013

     September 5, 2013
509. International PLRs of the 34th week of 2013

     September 5, 2013
510. International PLRs of the 33rd week of 2013

     September 5, 2013
511. International PLRs of the 32nd week of 2013

     September 5, 2013
512. International PLRs of the 31st week of 2013

     September 5, 2013
513. International PLRs of the 30th week of 2013

     September 5, 2013
514. International PLRs of the 29th week of 2013

     September 5, 2013
515. International PLRs of the 28th week of 2013

     September 5, 2013
516. Famous Tax Quotes - Double Taxation Cannot Always Be Avoided

     August 30, 2013
517. Situational Charts of Examples 8 and 9 of Treas. Reg. §1.1361-5(b)(3) - Terminations of Qsub Elections

     August 29, 2013
518. International PLRs of the 27th week of 2013

     August 29, 2013
519. International PLRs of the 26th week of 2013

     August 29, 2013
520. International PLRs of the 25th week of 2013

     August 29, 2013
521. International PLRs of the 24th week of 2013

     August 29, 2013
522. Famous Tax Quotes - "Bureaucrats"

     August 28, 2013
523. Famous Tax Quotes - Separate Entity Doctrine

     August 28, 2013
524. International PLRs of the 23rd week of 2013

     August 26, 2013
525. International PLRs of the 22nd week of 2013

     August 26, 2013
526. International PLRs of the 21st week of 2013

     August 25, 2013
527. International PLRs of the 20th week of 2013

     August 25, 2013
528. International PLRs of the 19th week of 2013

     August 25, 2013
529. Situational Chart of Rev. Rul. 78-401 - No Meaningful Reduction In The Shareholder's Proportionate Interest

     August 24, 2013
530. International PLRs of the 18th week of 2013

     August 23, 2013
531. International PLRs of the 17th week of 2013

     August 22, 2013
532. International PLRs for the 16th week of 2013

     August 21, 2013
533. International PLRs of the 15th week of 2013

     August 20, 2013
534. International PLRs of the 14th week of 2013

     August 19, 2013
535. International PLRs of the 13th week of 2013

     August 18, 2013
536. International PLRs of the 12th week of 2013

     August 16, 2013
537. IRS Rules Commission Income From Sales is Not FBCSI

     August 16, 2013
538. Number of Expatriates Skyrockets Again (Second Quarter of 2013)

     August 9, 2013
539. Tax Textbook Built Into Lamp

     July 21, 2013
540. Mandatory Electronic Filing for FBARs Coming Soon

     June 13, 2013
541. Daly v. Commr. - Abode Was in the U.S. - No Foreign Earned Income Exclusion Allowed

     June 12, 2013
542. Fideicomisos/Mexican Land Trusts are Not Trusts (Finally)

     June 6, 2013
543. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 1, 2013
544. Inbound Overview Flowchart (for Sale)

     May 10, 2013
545. Barnes Group - Structured Repatriation Was a Dividend

     May 10, 2013
546. Q1 2013 - Highest Quarterly Number of Expatriates Ever (But . . . )

     May 8, 2013
547. Section 911 Housing Cost Amounts Updated for 2013

     May 6, 2013
548. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2012)

     April 12, 2013
549. International PLRs & CCA of the 11th week of 2013

     March 22, 2013
550. International PLRs of the 10th week of 2013

     March 21, 2013
551. International PLRs of the 9th week of 2013

     March 4, 2013
552. International PLRs of the 8th week of 2013

     February 26, 2013
553. International PLR of the 7th week of 2013

     February 20, 2013
554. 48% Decrease in Number of Expatriates for 2012

     February 14, 2013
555. FATCA, NFFEs, and Draft W-8BEN-E - Unnecessary Complexity

     February 13, 2013
556. International PLR of the 6th week of 2013

     February 11, 2013
557. PLRs of the 5th week of 2013

     February 1, 2013
558. International PLRs of the 4th week of 2013

     January 26, 2013
559. Form 5471 Videos

     January 25, 2013
560. International PLRs of the 3rd week of 2013

     January 19, 2013
561. International PLRs for the 2nd week of 2013

     January 19, 2013
562. Free Section 351 Exchange Flowchart

     January 18, 2013
563. International PLRs of the 1st week of 2013

     January 4, 2013
564. Senate Fiscal Cliff Bill Includes Retroactive Reinstatement of CFC Look-Thru Rule

     January 1, 2013
565. International PLRs of the 52nd Week of 2012

     December 28, 2012
566. International PLRs & CCA’s of the 51st week of 2012

     December 27, 2012
567. International PLRs for the 50th week of 2012

     December 20, 2012
568. Teaching International Tax at Quinnipiac University School of Law

     December 20, 2012
569. International PLRs of the 49th week of 2012

     December 13, 2012
570. Doctrine of Constructive Receipt

     December 13, 2012
571. International PLRs of the 48th week of 2012

     November 30, 2012
572. Summary of Form 8938 Filing Thresholds

     November 28, 2012
573. International PLRs of the 47th week of 2012

     November 24, 2012
574. International PLRs of the 46th week of 2012

     November 24, 2012
575. International PLRs of the 45th week of 2012

     November 24, 2012
576. IRS Rules that Mexican Fideicomiso is Not a Trust

     November 15, 2012
577. International PLRs of the 44th week of 2012

     November 10, 2012
578. Graphic on Inbound & Outbound

     November 7, 2012
579. International PLRs of the 43rd Week of 2012

     November 5, 2012
580. International PLRs of the 42nd week of 2012

     November 5, 2012
581. International PLRs for the 41st week of 2012

     November 5, 2012
582. International PLRs of the 38th, 39th & 40th weeks of 2012

     November 3, 2012
583. Expatriates for the Third Quarter of 2012

     November 1, 2012
584. USD School of Law - Procopio International Tax Institute

     October 26, 2012
585. 2013 Inflation Adjustments for Individuals in the International Tax Arena

     October 23, 2012
586. Repatriate Now? (Before the Bush Tax Cuts Expire)

     October 19, 2012
587. Form 1099 for Payments to Foreign Contractors for Services?

     October 7, 2012
588. Senate Committee Video Testimony - Offshore Profit Shifting

     October 1, 2012
589. International PLRs of the 37th week of 2012

     September 15, 2012
590. 8th Annual USD School of Law-Procopio International Tax Law Institute (Oct. 25th & 26th)

     September 10, 2012
591. International PLRs of the 36th week of 2012

     September 8, 2012
592. Famous Tax Quotes - Accounting Firm "Screw Up"

     September 5, 2012
593. International PLR of the 35th week of 2012

     September 4, 2012
594. Partnership Definition

     September 4, 2012
595. Gratuitous Links to Local Visiting Nurses Association

     September 2, 2012
596. Canada & U.S. to Apply the Authorized OECD Approach (“AOA”) for Attribution of Business Profits

     September 2, 2012
597. Belgian Municipal and Conurbation Income Taxes are Covered by the Treaty

     August 31, 2012
598. International PLRs of the 34th week of 2012

     August 25, 2012
599. International PLR of the 33rd week of 2012

     August 25, 2012
600. International PLRs of the 32nd week of 2012

     August 25, 2012
601. International PLRs & CCA of the 31st week of 2012

     August 24, 2012
602. International PLRs of the 30th week of 2012

     August 24, 2012
603. 189 Published Expatriates for Q2 of 2012

     August 2, 2012
604. Joint FATCA Implementation Statements

     July 21, 2012
605. International PLRs of the 29th week of 2012

     July 21, 2012
606. International PLRs of the 28th week of 2012

     July 21, 2012
607. International PLRs of the 26th week of 2012

     July 21, 2012
608. International PLR of the 25th week of 2012

     July 21, 2012
609. International PLRs of the 24th week of 2012

     June 16, 2012
610. International PLRs of the 23rd week of 2012

     June 12, 2012
611. International PLRs of the 22nd week of 2012

     June 12, 2012
612. International PLR of the 21st week of 2012

     June 11, 2012
613. International PLRs of the 20th week of 2012

     June 11, 2012
614. Links to Expatriate Lists

     June 8, 2012
615. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 2, 2012
616. Update on 1997 Expatriation Data

     June 1, 2012
617. Example of a Mini-Eduardo Saverin

     May 18, 2012
618. Book Review: Transfer Pricing Answer Book 2012

     May 15, 2012
619. International PLRs of the 19th week of 2012

     May 14, 2012
620. All Cash D Reorganization Video - Example 16, Loss of Basis

     May 9, 2012
621. All Cash D Reorganization Video

     May 2, 2012
622. 460 Published Expatriates for Q1 of 2012

     April 29, 2012
623. International PLRs of the 15th and 16th Weeks of 2012

     April 23, 2012
624. Spin-Off to Foreign Parent Video

     April 21, 2012
625. Aiken Industries Video

     April 17, 2012
626. Brazilian tax package

     April 11, 2012
627. International PLRs of the 14th week of 2012

     April 10, 2012
628. International PLRs of the 13th week of 2012

     April 1, 2012
629. International PLRs of the 12th week of 2012

     March 29, 2012
630. B Reorganization Video

     March 24, 2012
631. 1997 Had More U.S. Expatriations Than 2011

     March 19, 2012
632. International PLRs of the 10th week of 2012

     March 16, 2012
633. Attorney-Client Privilege Flowchart

     March 15, 2012
634. International PLRs / CCAs of the 8th week of 2012

     March 2, 2012
635. 10 Free New Tax Charts (Feburary 2012)

     March 2, 2012
636. Section 911 Housing Cost Amounts Updated for 2012

     February 14, 2012
637. International PLRs / CCAs of the 6th week of 2012

     February 12, 2012
638. Famous Tax Quotes - Same Boat But Another Ocean

     February 5, 2012
639. International PLRs / CCAs of the 5th week of 2012

     February 3, 2012
640. Number of Expatriates for 2011

     February 2, 2012
641. International PLRs / CCAs of the 4th week of 2012

     January 30, 2012
642. International Aspects of Mitt Romney’s 2010 Tax Return

     January 27, 2012
643. International PLRs of the 3rd week of 2012

     January 26, 2012
644. Uncompensated Use of Foreign Trust Property

     January 25, 2012
645. Income Accruing in Foreign Retirement Plans

     January 22, 2012
646. New FBAR (Again) - Email Your Questions

     January 20, 2012
647. International PLRs of the 2nd week of 2012

     January 20, 2012
648. International PLRs of the 1st week of 2012

     January 6, 2012
649. International PLRs of the 52nd Week of 2011

     December 31, 2011
650. International PLRs of the 51st Week of 2011

     December 23, 2011
651. This Post Has Been Updated

     December 23, 2011
652. International PLRs of the 50th Week of 2011

     December 20, 2011
653. Code §951 Inclusions Are Not Qualified Dividend Income

     December 17, 2011
654. International PLRs of the 49th Week of 2011

     December 12, 2011
655. Loan With “Kicker” is a USRPI

     December 8, 2011
656. International PLRs of the 47th Week of 2011

     November 26, 2011
657. International PLRs of the 46th Week of 2011

     November 18, 2011
658. Subpart F Income

     November 14, 2011
659. International PLRs of the 43rd Week of 2011

     November 11, 2011
660. International PLRs of the week

     October 25, 2011
661. 2012 Inflation Adjustments for Individuals in the International Tax Arena

     October 24, 2011
662. New Brunswick Premier Caught in U.S. Tax Net

     October 3, 2011
663. Goosen v. Commr. - Golfer Endorsement Fees

     August 23, 2011
664. Notice 2011-64: Countries Qualifying for Reduced Dividend Tax Rates

     August 18, 2011
665. Q2 of 2011 Had the Second Highest Number of “Published Expatriates”

     August 17, 2011
666. U.K. Remittance Basis Charge (“RBC”) is a Creditable Tax

     August 15, 2011
667. Dagres - Ordinary Loss for Bad Debt of Private Equity Fund Manager

     August 12, 2011
668. Double Taxation on Services

     July 26, 2011
669. The “Repatriation IRA” [To Stimulate the Economy]

     July 7, 2011
670. Is the Limitation On Benefits Provision in the Proposed Hungary Treaty Too Complex?

     July 7, 2011
671. Free Section 736 Flowchart

     July 6, 2011
672. YouTube Video on Busted Section 351 Exchanges

     June 29, 2011
673. Flowchart of LOB Article of Chile-U.S. Income Tax Treaty

     June 27, 2011
674. U.S. Government Continues to Pursue Taxpayers Committing Tax Fraud

     June 24, 2011
675. Famous Tax Quotes - Transactions Between Related Parties Merit Extra Scrutiny

     June 23, 2011
676. IRS Delays Annual Reporting for Foreign Financial Assets and P.F.I.C.s

     June 21, 2011
677. This Post Has Been Updated

     June 17, 2011
678. Additional Extension for Pre-2010 Signature Authority Only FBARs

     June 16, 2011
679. Two New Flowcharts on Tax-Charts.com

     June 13, 2011
680. U.S. Citizens Continue to Renounce

     June 10, 2011
681. 10 Free New Tax Charts (June 2011)

     June 10, 2011
682. Offshore Structure to Hold Iraqi Dinars?

     May 23, 2011
683. Flowchart of Rev. Proc. 93-27

     May 12, 2011
684. Doctrine of Cloth[e]ing

     May 2, 2011
685. Should “goodwill” be one word or two words?

     March 31, 2011
686. IRS Reporting of Bank Interest Paid to NRAs

     March 29, 2011
687. Famous Tax Quotes - Valuation Is Not an Exact Science

     March 22, 2011
688. NPR Podcast on Double Irish Structure

     March 18, 2011
689. Famous Tax Quotes - Very definitely . . . probably

     March 17, 2011
690. Famous Tax Quotes - Congress Can "label a thing income and tax it"

     March 9, 2011
691. Number of Expatriates More Than Doubles

     March 4, 2011
692. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2010)

     February 28, 2011
693. 30% Tax for Interest Paid on Foreign Margin Account of U.S. Resident

     February 23, 2011
694. Famous Tax Quotes - Seduced by a Siren Song of Symmetry

     February 18, 2011
695. CCA 201106007 - Investments in U.S. Property - Intangibles

     February 14, 2011
696. Famous Tax Quotes - Drawing Lines

     February 10, 2011
697. PLR 201105011 Allows Re-Election of Revoked Code §911 Foreign Earned Income Exclusion

     February 6, 2011
698. Section 911 Housing Cost Amounts Updated for 2011

     February 2, 2011
699. 10 Free New Tax Charts (Jan. 2011)

     January 20, 2011
700. Terminology for Hybrid Entities & Hybrid Instruments

     January 19, 2011
701. Famous Tax Quotes - Too Good To Be True . . .

     December 28, 2010
702. Famous Tax Quotes - A “Hat Problem”

     December 27, 2010
703. Google Ngrams for Selected Tax Terms

     December 21, 2010
704. Code § 954(c)(6) C.F.C. Look-Thru Rule Retroactive Reinstatement

     December 17, 2010
705. 10 Free New Tax Charts

     December 7, 2010
706. Famous Tax Quote #37 - Is Fido a dog?

     December 7, 2010
707. Famous Tax Quote #36 - Differences in Degree vs. Differences in Kind

     November 11, 2010
708. International Financial Scams - Overseas Investments, Lotteries, Inheritances, Gifts, etc.

     November 2, 2010
709. Famous Tax Quote #35 - Foresight and Planning

     October 31, 2010
710. 2011 Inflation Adjustments for Individuals in the International Tax Arena

     October 28, 2010
711. Two New Flowcharts

     October 27, 2010
712. Google’s Use of Double Irish Structure

     October 21, 2010
713. Expatriations Continue Upward Trend

     October 21, 2010
714. OECD Commentary on Electronic Commerce for Permanent Establishments

     October 18, 2010
715. Free Flowchart of Rev. Proc. 2009-41

     October 12, 2010
716. Famous Tax Quote #34 - A Word is Not a Crystal

     September 24, 2010
717. Famous Tax Quote #33 - A melody is more than the notes

     September 20, 2010
718. Software Classification Flowchart

     September 16, 2010
719. Famous Tax Quote #32 - Change in the tax laws is a way of life

     September 3, 2010
720. Tax Crimes, Tax Fraud, Tax Schemes

     August 30, 2010
721. Famous Tax Quote #31 - If Pigs Had Wings, They Could Fly

     August 25, 2010
722. Famous Tax Quote #30 - A Judicial Moon

     August 17, 2010
723. New Section 956 Foreign Tax Credit Blending Rule

     August 13, 2010
724. Should Congress Force An Accounting Rule Change?

     July 28, 2010
725. Hybrid Entities and Reverse Hybrid Entities

     July 27, 2010
726. Famous Tax Quote #29 - Taxing Corporate Distributions

     July 4, 2010
727. Famous Tax Quote #28 - Purpose of Subpart F Income

     June 27, 2010
728. What is a “check-the-box” election?

     June 25, 2010
729. Famous Tax Quote #27 - All of life is a risk

     June 13, 2010
730. Famous Tax Quote #26 - Business Purpose / Economic Substance

     June 6, 2010
731. U.S. Model Treaty: Limitation on Benefits Flowchart

     June 3, 2010
732. Famous Tax Quote #25 - Broker vs. Dealer

     May 30, 2010
733. Covered Expatriate Flowchart

     May 27, 2010
734. Subpart F Income Partnership Blocker Update

     May 25, 2010
735. Famous Tax Quote #24 - Name for a Partnership With No Business Purpose

     May 23, 2010
736. Double Irish Structure - Time for a New Tax Penalty?

     May 20, 2010
737. Pensions Under the Belgium-U.S. Income Tax Treaty

     May 18, 2010
738. Famous Tax Quote #23 - Motives Immaterial in a Code § 368(a)(1)(D) Reorganization

     May 16, 2010
739. Canada-U.S. Treaty - Guidance on Deemed Sale/Purchase Election

     May 13, 2010
740. Famous Tax Quote #22 - Redemption as a Step in a Reorganization

     May 11, 2010
741. Foreign “EZ Pass” --- A Foreign Financial Account?

     May 7, 2010
742. Sourcing By Analogy

     May 2, 2010
743. Famous Tax Quote #21 - The Words Dance Before My Eyes

     May 2, 2010
744. New PFIC Annual Reporting Rules

     April 7, 2010
745. Beware Gifts to Non-Citizen Spouses

     April 2, 2010
746. New Foreign Asset Disclosure Rules Enacted

     March 20, 2010
747. A Circumvention of the Spirit of the Law?

     March 19, 2010
748. U.S. Expatriations Skyrocket

     March 1, 2010
749. Guarantee Fees Analogized as Services

     February 18, 2010
750. IRS Rulings on Manufacturing Branch Rule

     February 11, 2010
751. Cash D Reorganizations & the Meaningless Gesture Doctrine

     February 11, 2010
752. Famous Tax Quote #20 - Tax Reduction Is Not Evil

     February 10, 2010
753. Section 911 Foreign Earned Income Excl'n - Adverse Conditions (2009)

     February 5, 2010
754. Famous Tax Quote #19 - How many legs does a dog have?

     February 3, 2010
755. 97th Anniversary of the 16th Amendment

     February 3, 2010
756. Offshore Bearer Bonds

     January 8, 2010
757. Alice in Wonderland

     December 31, 2009
758. Sourcing Rules for Telecoms’ International Communications Income

     December 20, 2009
759. Famous Tax Quote #18 - "Dummy" Corporations

     December 16, 2009
760. Famous Tax Quote #17 - Taxation depends on actual events

     December 8, 2009
761. Famous Tax Quote #16 - Taxation is Not Cuneiform.

     December 5, 2009
762. Famous Tax Quote #15 - Simple Expedient of Drawing Up Papers

     December 2, 2009
763. Liechtenstein Anstalts & Stiftungs

     November 24, 2009
764. Expatriations on the Rise Again

     November 19, 2009
765. Famous Tax Quote #14 - Mere Formalisms

     November 16, 2009
766. Famous Tax Quote #13 - Anticipatory Assignment

     November 13, 2009
767. Famous Tax Quote #12 - Income Is Taxed to The Earner

     November 4, 2009
768. Overseas Inheritance Scam: Tax Certificate for Wire Transfer

     October 14, 2009
769. FBAR Reporting for Foreign Mutual Funds

     September 18, 2009
770. Three Manufacturing Tests Under Code § 954(d) & the Manufacturing Branch Rules

     September 11, 2009
771. Green Card Holders Living Outside the U.S.

     September 10, 2009
772. Schering-Plough Corp. v. U.S.

     September 5, 2009
773. Famous Tax Quote #11 - Exalting Form Over Substance

     September 4, 2009
774. IRS Extends Due Date for Late Check-the-Box Elections

     September 3, 2009
775. Famous Tax Quote #10 - Meaningless Gesture

     September 2, 2009
776. Famous Tax Quote #9 - Origin of All Events Test

     August 28, 2009
777. Widely Held vs. Closely Held

     August 26, 2009
778. “Inbound” & “Outbound”

     August 24, 2009
779. Free Code § 302 Redemption Flowchart

     August 19, 2009
780. Famous Tax Quote #8 - Tax Rules Don't Necessarily Make Sense

     August 14, 2009
781. Famous Tax Quote #7 - Contingent Liabilities

     August 10, 2009
782. Tax Chart Shape & Color Conventions

     July 31, 2009
783. Famous Tax Quote #6 - Presumption of Correctness

     July 30, 2009
784. Foreign Deferral Matching Principle

     July 20, 2009
785. Famous Tax Quotes #4 & #5 - No Patriotic Duty to Increase Taxes

     July 14, 2009
786. Famous Tax Quote #3 - Deductions Legislative Grace

     July 10, 2009
787. Famous Tax Quote #2 - What Actually Occurred

     July 5, 2009
788. Famous Tax Quote #1 - Straight Path / Devious Path

     July 3, 2009
789. Qualified Business Units (QBUs)

     June 30, 2009
790. IRS Additional FAQs Regarding Filing of FBAR and other Cross-Border Tax Forms

     June 26, 2009
791. UBS Client Pleads Guilty to Filing False Tax Return

     June 25, 2009
792. Branch Rule Complexity Continued

     May 12, 2009
793. Branch Rule Complexity

     May 12, 2009
794. Deemed Permanent Establishment, But Not Carrying On Business

     May 1, 2009
795. Offshore Asset Protection Misconceptions

     April 28, 2009
796. IRS Finally Publishes 2008 Form 8804

     March 22, 2009
797. Modifications to Section 367 in Outbound Section 304 Transactions

     February 27, 2009
798. “Unrelated” Financial Institution Under U.S.-Australia Income Tax Treaty

     February 2, 2009
799. Treaty Limits on Reduced Dividend Withholding Rates for U.S. Mutual Funds

     December 31, 2008
800. Ireland - What’s Not to Like?

     December 2, 2008
801. Foreign Bank Secrecy & Tax Evasion

     November 26, 2008
802. Irish Times: “Obama could be bad for Ireland”

     October 27, 2008
803. Treasury Department’s Billion Dollar Tax Bailout for Banks By Fiat

     October 1, 2008
804. Poor Grammar in Drafting of CFC Statutes

     September 22, 2008
805. Section 367 - Exceptions Upon Exceptions

     August 22, 2008
806. IRS Shuts Down Another Repatriation Technique

     August 8, 2008
807. New Tax Charts

     July 18, 2008
808. 5 Charts of Non-U.S. Tax Cases

     July 10, 2008
809. Chart of Killer Forward Triangular Merger

     July 7, 2008
810. IRS to Scrutinize International Transactions of Smaller Companies

     July 6, 2008
811. New Expatriation Rules for High Net Worth Individuals

     June 29, 2008
812. Treasury Issues Regulations to Close Repatriation Loophole

     June 22, 2008
813. U.S. “State” Tax Residency (Domicile)

     June 1, 2008
814. Canadian Outbound Taxation

     May 25, 2008
815. Treaty Shopping & Anti-Treaty Shopping

     May 18, 2008
816. Bulgarian Aktsionerno Druzhestvo Added To Per Se Corporation List

     May 4, 2008
817. Inheriting Foreign Real Estate Inside a Foreign Corporation

     April 6, 2008
818. U.S. Competitiveness and Corporate Tax Rates

     March 30, 2008
819. Electronic Arts Chart

     March 23, 2008
820. The Foreign Base Company Sales Income “Manufacturing Exception”

     March 13, 2008
821. Third Circuit Reverses Tax Court in Swallows Holdings

     February 25, 2008
822. Foreign Vacation Homes & Rental Properties

     February 8, 2008
823. Practitioner Cross-Border Activities Can be Costly

     February 6, 2008