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The Cautionary Tale of the Malta Pension Plan: First, Civil Audits, Now Criminal Investigations

Few things scare a taxpayer more than the IRS knocking on their door. But when the taxpayer realizes that the person knocking on the door is a Special Agent of the Criminal Investigation Division (“CID”) of the IRS, well…...more

[Webinar] The Freeman Law International Tax Symposium - October 20th - 21st, 9:00 am - 5:00 pm CST

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more

The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with...

The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with international assets/accounts. The IRS has just released Notice 2022-36 which provides an...more

[Webinar] Preparing Form 5472 step by step instructions - February 22nd, 12:00 pm - 2:00 pm CT

You are invited to Freeman Law Tax Academy Series - FORM 5472: STEP BY STEP INSTRUCTIONS - Learning Objectives: - Determine the applicability of Form 5472 - Properly complete Form 5472 - Identify prospective...more

Donkeys and Taxes

Hobby Loss or Business Loss Tax Deduction - It’s not every day that a case comes through the Tax Court centered on the taxation of miniature donkey breeding. But the recent case of Huff v. Commissioner was focused on just...more

Is your Foreign Tax Credit really creditable? Think again: Revisiting the basics of the Foreign Tax Credit.

As discussed in a previous article, the Foreign Tax Credit (FTC) is a bedrock of the U.S. tax system to reduce the impact of double taxation. In general terms, income that is derived from a foreign jurisdiction by a U.S....more

Happy New $YEAR: How to deduct crypto losses on your 2021 tax return

2021 was an incredible year for crypto investors. Tokens such as Polygon ($MATIC), Sandbox ($SAND), Decentraland ($MANA) had incredible gains, with investors realizing returns in excess of 100% of their original investment....more

[Webinar] Updates: IRS Tax Enforcement, Taxation of Settlements, and Cross-Border Tax Planning - August 31st, 3:00 pm CT

Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights. During this information-filled...more

Recent Tax Court Case and Theft-Loss Deductions

A recent Tax Court case dealt with a familiar topic: Theft losses. I.R.C. section 165 has historically allowed taxpayers to deduct three types of losses: those incurred in a trade or business, those incurred in a transaction...more

U.S. Digital Service Providers with Mexican customers: Avoid being ¨shut-down¨ in Mexico

COVID times has brought us tough changes in our lives, and tax reform is one of them. In the U.S., the CARES Act provided relief to multiple sectors of the economy to alleviate the impact of the pandemic. However, the...more

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