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Latest developments (and Killspencer)

Phil Hodgen December 25, 2015

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...

Late FBAR filing and penalties

Phil Hodgen November 12, 2008

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...

ILM 200504029

Phil Hodgen January 31, 2005

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...