The Supreme Court recently ruled in Bittner vs. United States that federal law prescribes that maximum penalties for the non-willful failure to file a report are calculated per report, not per account. In Bittner, the Court was tasked with interpreting the…
After the presidential election, some citizens planned on renouncing their citizenship and moving abroad to Canada, or elsewhere. It would be interesting to survey those who stated this proposition to see if they followed through on their promise (or threat).…
IRC § 911(b)(1)(A) provides the definition of “foreign income.” For tax purposes, this provision is important because If certain requirements are met, a taxpayer may qualify for the foreign earned income, foreign housing exclusions and the foreign housing deduction. Under certain…
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