Seattle International Tax Attorney Blog

RECENT TAX CUTS AND JOBS ACT ARTICLES

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IRS Publishes Guidance on Application of Section 965 for 2017 Tax Year Filings

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The Interest Charge Domestic International Sales Corporation ("IC-DISC") after the Tax Cuts and Jobs Act

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International Tax Law Changes - A Look at the CFC Attribution Rules after the Tax Cuts and Jobs Act 

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RECENT INTERNATIONAL TAX ARTICLES

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Court Reviews Reasonable Cause Standard in Recent Case

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Willful FBAR Penalty Against Taxpayer Sustained

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FBAR Penalty in Excess of $100,00 allowed where multiple counts of FBAR violations

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IRS Announces New Voluntary Disclosure Program for Delinquent International Filings and Foreign Bank Accounts

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FBAR Penalty Does Not Terminate at Death

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IRS Provides Guidance on Standard for Definition of Willfulness under FBAR

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IRS to end Offshore Voluntary Disclosure Program "OVDP"

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Definition of "Willful" in FBAR and OVDP Context Examined by Recent Court Case

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Streamline Offshore Filing Procedure - Application of the Non-Residency Rules to Taxpayers with Foreign Bank Accounts

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Tax Court disallows Section 911 Exclusion due to late filing

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Key Differences Between FBAR & FATCA Filing Requirements

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Tax Court Revisits Definition of "Abode" under Section 911 in Recent International Tax Case

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PFIC Filing Requirements, Who Must File PFIC Form 8621 & For What Tax Years

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UPCOMING AND RECENT INTERNATIONAL TAX PRESENTATIONS

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University of Washington - UW T523 - International Estate Planning

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Panelist: Washington Society of Certified Public Accountants, International Tax Conference 2018

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Panelist: Foreign Personal Holding Company Income Reporting: Mastering Subpart F Inclusions and Deemed Dividend Rules​

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Panelist: Form 8621 PFIC Reporting: Navigating the Highly Complex IRS Passive Foreign Investment Company Rules

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Presentation: Basics of International Tax Planning​ for Attorneys and CPAs

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Bloomberg BNA: International Taxation of Computer Software under Reg. Sec. 1.861-18 & Cloud Computing Transactions

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UPCOMING AND RECENT INTEREST CHARGE DOMESTIC INTERNATIONAL SALE CORPORATION (IC-DISC) PRESENTATIONS

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University of Washington - International Estate Planning - Tax LLM Program - UWT523 

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IC-DISC Tax Planning - Estate Tax Benefits - Estate Planning Council Presentation

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IC-DISC: Tax Law Challenges

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Bloomberg BNA - How to Reduce Tax Obligations Using IC-DISCs - for attorneys and CPAs

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IC-DISC Tax Planning - Life after Summa Holdings v. Commissioner

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Panelist: IC-DISC Tax Law Challenges: Structuring and Planning Techniques to Maximize Federal Tax Savings