The IRS has tools inside of its Internal Revenue Manual (“IRM”) available to its agents for determining a Taxpayer’s taxable income as well as documenting its adjustments and corrections through what it calls “Methods of...more
Ever since the advent of FATCA and related global tax transparency movements, U.S. individuals living abroad have likely become far too acquainted with the challenges posed by holding U.S. citizenship or residency. Perhaps...more
When the 2017 Tax Cuts and Jobs Act was passed, significant changes were made to the Federal Estate, Gift and Generation-Skipping Transfer Tax, the most prominent of which is the increased applicable exclusion amount, which...more