Guest Article
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Guest Post: Make Your American Dream a Reality

Guest Writer:  Michael Longsdon of ElderFreedom.net* Immigrants moving to the United States often have their hands full with immigration paperwork, assimilation into their new communities, and even tax considerations. Despite these challenges, many come with a vision of the American dream. Use this guide to help you make your American Dream a reality! Down to Business Many new transplants are eager to find a way to support loved ones back in their home country. Sometimes,

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International Issues
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A Necessary Conversation: Explaining FBAR Filings to the Uninitiated

Explaining FBAR Filings to the Uninitiated This is not the normal Briefly Taxing post.  Usually, I post articles written exclusively for the blog, but today I am excited to post an article I wrote for someone else. In late July, I received a comment on the blog from an editor at Bloomberg Law, saying that she had read one of my posts, and asking whether I would be willing to write for them.   I

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International Issues
Tax Articles

A Primer on FIRPTA Withholding

At its most basic, any disposition of a U.S. real property interest by a foreign person (as transferor) is subject to the Foreign Investment in Real Property Act of 1980, more commonly known as FIRPTA.[1] So, when a foreign person or entity sells, transfers, or otherwise disposes of a piece of U.S. real property, the transferee will likely have to withhold a certain percentage of the sales price.[2] Defining Disposition The term disposition as used

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Procedural Issues
Tax Articles

The Streamlined Filing Compliance Procedures

In an increasingly common occurrence, a client calls in somewhat of a tizzy over foreign information returns, which, apparently, she was “required” to file for the past few years. She’s gone to three different CPAs, only the last one of which even asked her whether she had foreign assets or interests. Her new CPA, one of the good ones, inquired about any foreign relationships that she might have, and she disclosed a Swiss bank account,

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Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied;

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Middleton v. Commissioner
T.C. Memo. 2022-28

On April 4, 2022, the Tax Court issued a Memorandum Opinion in the case of Middleton v. Commissioner (T.C. Memo. 2022-28). The primary issues presented in Middleton v. Commissioner were (i) whether the taxpayer could challenge the Trust Fund Recovery Penalty at his CDP hearing; and (ii) whether the taxpayer

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Villanueva v. Commissioner
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On March 31, 2022, the Tax Court issued a Memorandum Opinion in the case of Villanueva v. Commissioner (T.C. Memo. 2022-27). The primary issue presented in Villanueva v. Commissioner was whether the petitioner was entitled to a net operating loss deduction. Held: Sorry, Edgardo, not today. Background to Villanueva v.

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On March 29, 2022, the Tax Court issued a Memorandum Opinion in the case of Golditch v. Commissioner (T.C. Memo. 2022-26). The primary issues presented in Golditch v. Commissioner were (i) whether the taxpayer was permitted to challenge his underlying tax liability at CDP hearing; (ii) whether the taxpayer’s argument

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Porter v. Commissioner
T.C. Memo. 2022-25

On March 28, 2022, the Tax Court issued a Memorandum Opinion in the case of Porter v. Commissioner (T.C. Memo. 2022-25). The primary issues presented in Porter v. Commissioner were whether (i) delays in examination and litigation were attributable to IRS officer or could significantly be attributed to taxpayer; and

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Addis v. Commissioner
T.C. Memo. 2022-24

On March 28, 2022, the Tax Court issued a Memorandum Opinion in the case of Addis v. Commissioner (T.C. Memo. 2022-24). The primary issue presented in Addis v. Commissioner was whether the frivolous taxpayer’s CDP rights had been violated. Held: Not quite, Jonah. Mr. Addis’s 2014 Tax Reporting On March

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