Seattle International Tax Attorney Blog

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

Strafford Publications has recently asked me to join a panel of attorneys and CPAs to provide insight into the PFIC rules and related filing requirements. This presentation will cover...

Doing Business in Iran After the Nuclear Agreement

Strafford Publications has recently asked me to join a panel of attorneys to discuss doing business in Iran after the Nuclear Agreement. The audience will include business and tax attorneys and CPAs with clients interested in entering the Iran...

Bloomberg BNA Presentation: International Taxation of Computer Software and Cloud Computing Transactions

Bloomberg BNA Tax has asked me to speak at an upcoming event covering international taxation of computer software and cloud computing transactions. The presentation will be made to tax attorneys and CPA, and will cover...

FBAR Filing Deadline Set to Change

Certain U.S. taxpayers with foreign financial accounts are required to file annually the Form FinCin114, commonly referred to as the "FBAR". As part of recent legislation signed by President Obama, the due date for the FBAR...

Bloomberg BNA Presentation: Basics of International Tax Planning

Bloomberg BNA Tax has asked me to speak at an upcoming event covering the basics of international tax planning. The presentation will be made to business and tax attorneys and cpas who deal with clients with international business....

Bloomberg BNA Presentation: IC-DISC: Big Tax Benefits for Export Clients

Bloomberg BNA Tax has asked that I present on the interest charge domestic international sales corporation (IC-DISC). The presentation covers IC-DISC qualification requirements, IC-DISC maintenance....

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

I was recently asked to join a panel presentation made to attorneys and CPAs. The presentation provided tips to tax attorneys on implementation and maintenance of DISC....... 

Tax Court revisits definition of "abode" within context of Section 911 in recent international tax case. 

Section 911 provides a foreign earned income tax exclusion for U.S. taxpayers working abroad. In a recent international tax case, the Tax Court revisits the applicable law under Section 911....

New Streamlined Offshore Compliance Program Provides Expanded Avenue to International Tax Compliance for U.S. Individuals

The expanded Streamline Offshore Compliance Progam provides an great opportunity for individuals within the greater Seattle area, and nationally, to become compliant with the IRS on international tax filing....

IC-DISC Export Tax Incentive Benefits, Strategies & Commissions

I was asked recently to speak to a group of attorneys and CPAs in Seattle regarding the benefits of the IC-DISC export tax incentive. This presentation provides the benefits, along with some planning...

Basics of International Tax for Attorneys

I was recently asked to speak at the Washington State Bar Association Annual Tax Section CLE. The presentation to Seattle attorneys covered basics of international tax for lawyers with international clients...

PFIC Filing Requirements, Who Must File PFIC Form 8621

Recently released temporary regulations reverse prior IRS guidance relating to retroactive filing requirement for investments in Passive Foreign Investment Company (“PFIC”). Section 1298(f) requires...