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Recent Articles

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...

Exit Tax Book Chapter 6: Mark-to-Market Taxation

Debra Rudd June 07, 2019

Last month, I explained how to determine if you are a covered or non-covered expatriate. The major difference between covered and non-covered expatriates is that...

Minimultinationals Chapter 01: Overview of the Series

Phil Hodgen February 01, 2019

American minimultinationals are small (for various definitions of "small") business enterprises subjected to the U.S. tax system. There are many ways that a minimultinational becomes...

American Minimultinationals: An Introduction

Phil Hodgen January 18, 2019

What's an American Minimultinational? What do I mean by American minimultinational? Multinational A multinational business operates in multiple countries, exposed to multiple tax-hungry governments. Apple....