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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Hamilton v. Commissioner
T.C. Memo. 2022-21

On March 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Hamilton v. Commissioner (T.C. Memo. 2022-21). The primary issues presented in Hamilton v. Commissioner were (1) whether the Tax Court would consider taxpayers’ testimony and documentary evidence; (2) whether the notices of determination contained plain

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Bunton v. Commissioner
T.C. Memo. 2022-20

On March 10, 2022, the Tax Court issued a Memorandum Opinion in the case of Bunton v. Commissioner (T.C. Memo. 2022-20). The primary issues presented in Bunton v. Commissioner were (1) whether Brian and Karen were entitled to challenge the existence and amounts of their underlying tax liabilities for the

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DelPonte v. Commissioner
158 T.C. No. 7

On May 5, 2022, the Tax Court issued the full opinion in DelPonte v. Commissioner (158 T.C. No. 7). The primary issue presented in DelPonte v. Commissioner was whether the IRS’s Cincinnati Centralized Innocent Spouse Operation (CCISO) or the IRS’s Office of Chief Counsel has the final authority to determine

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Treece Financial Services Group v. Commissioner
158 T.C. No. 6

On April 19, 2022, the Tax Court issued the full opinion in Treece Financial Services Group v. Commissioner (158 T.C. No. 6). The primary issue presented in Treece Financial Services Group v. Commissioner was whether the Tax Court had jurisdiction to determine whether Voluntary Classification Settlement Program (VCSP) entered into

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BATS Global Markets Holdings Inc. v. Commissioner
158 T.C. No. 5

On March 31, 2022, the Tax Court issued the full opinion in BATS Global Markets Holdings Inc. v. Commissioner (158 T.C. No. 5). The primary issue presented in BATS Global Markets Holdings Inc. v. Commissioner was whether the petitioner’s transaction fees, routing fees, and logical port fees qualify as domestic

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Aptargroup Inc. v. Commissioner
158 T.C. No. 4

On March 16, 2022, the Tax Court issued the full opinion in Aptargroup Inc. v. Commissioner (158 T.C. No. 4). The primary issue presented in Aptargroup Inc. v. Commissioner was whether the taxpayer was required to characterize stock in controlled foreign corporation using gross income method. Held: Yes, indeed it

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