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The World’s Worst Tax Strategy “How will they ever find out?” It’s a classic tax-planning strategy that works very well, until the day it doesn’t...

Hi, it's Phil Hodgen. Merry Christmas. (And no, I am not writing this on Christmas Day.) This is the biweekly Friday Edition, chock-full of international...

Here is a recent Private Letter Ruling which parses the combined effect of U.S. tax law and the current income treaty between the United States...

In emailed advice released today on Tax Notes Today (2010 TNT 137-56 for you TNT fans) the IRS issued a rare written piece of information...

Today's Wall Street Journal (link to the article is here, Rupert Murdoch, and be damned) there is non-tax verification of what I am seeing here....

I just received an email from someone based on the www.foreignbankaccountamnesty.com site. It raised a question that comes up often, so I figured I would...

This is something that comes up again and again. Nonresident owns raw land (just dirt, nothing on it). There are some costs incurred each year...

It isn't international tax (directly) but I'm solving this California corporate tax problem publicly so you don't have to lose a few brain cells. If...

I got an inquiry today from my FIRPTA.com website that I figured would be worth answering here, because it is a topic of general application....

Undeclared foreign bank accounts. It's a common question. "I have this foreign bank account, but I haven't been declaring it by filing Form TD F...

A reader of my November, 2008 article in California CPA Magazine (hi, David) called me and asked a question about the article. He wanted to...

The IRS Chief Counsel's office released a legal memorandum, ILM 200504029, which details exactly how the "net election" can be taken in the year of...

On December 8, 2004, the governments of France and the United States amended the Estate Tax Treaty between the two countries. It appears to contain...