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Recent Articles

What the Swiss settlement means

Phil Hodgen August 13, 2009

Jack Townsend has -- as usual -- a thoughtful analysis of the implications of the UBS settlement in which UBS will cough up a few...

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...

Options are real estate, too

Phil Hodgen June 06, 2005

Hot off the press! There's a new legal memorandum from the IRS about sale by a nonresident of an option to acquire U. S. real...

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...