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Recent Articles

Why Form 5471 Exists

Phil Hodgen February 17, 2023

Form 5471 exists because Subpart F (IRC §§951-965) exists. Or to be more precise, Form 5471 exists because Subpart F exists and taxpayers are smarter...

Super Short Covered Expatriate Status Check

Phil Hodgen July 11, 2022

General Information about "Covered Expatriate" Status There are three triggers that can cause you to be a covered expatriate. You only need one to be...

Net Worth Test Q&A

Debra Rudd January 22, 2021

This post is a collection of questions and answers from Debra Rudd’s January 15, 2021 International Tax Lunch webinar on the Net Worth Test. The...

Why a Section 962 Statement is Necessary

Phil Hodgen April 21, 2020

On July 10, 2020 I will  present a live Section 962 webcast that goes into excruciatingly painful detail about preparing a Section 962 tax return....

Dadon v. United States (2020)

Phil Hodgen April 03, 2020

I have posted the full text of this case to make it easy to cross-reference to my previous blog post discussing what happened here.  Don't...

New IRS Expatriation Compliance Initiative

Debra Rudd August 09, 2019

Recently the IRS announced that it will be rolling out a compliance initiative for expatriates. There is no information about how this program will work...