Dual Residency Conflicts: Tie-Breaker Rules Explained for High-Net-Worth Individuals
What Happens When a Non-U.S. Person Becomes Trustee of a U.S. Trust?
The Taxation of Trusts in France: A Guide for International Families
Key Considerations for Europeans Starting a Business in the U.S.
When an IRS Audit Becomes a Legal Problem
Tax-Efficient Repatriation of Foreign Earnings: Planning Considerations for Cross-Border Structures
Tax Residency Rules: Key Considerations for Non-U.S. Individuals and Businesses
GILTI, BEAT, and FDII Explained: Key U.S. International Tax Changes for Multinationals
Foreign Tax Credits Explained: How to Limit Exposure to Double Taxation on Cross-Border Income
How Transfer Pricing Rules Can Affect Your Global Supply Chain
Pre‑Immigration Tax Planning: Protecting Global Wealth Before Moving to the United States
Global Tax Planning 101: How to Build a Cross-Border Tax Strategy That Works
Christine Concepción Featured on The Scholar Wealth Podcast
U.S. Tax Traps for Non-U.S. Investors: What Foreign Owners Often Learn Too Late
Proposed IRC Section 899: U.S. Strikes Back at Discriminatory Foreign Taxes
On May 22, 2025, the U.S. House of Representatives narrowly passed the “One Big Beautiful Bill Act”, a $3.8 trillion tax reconciliation package. Tucked inside is the proposed Section 899, a powerful new provision targeting what the U.S. considers discriminatory foreign tax practices.
When TurboTax Isn't Enough: What the Huang Case Teaches About Reasonable Cause
In an increasingly digital world, many taxpayers turn to tax preparation software like TurboTax to file their returns. However, the recent case of Huang v. United States (N.D. Cal. 2025) highlights the risks of relying solely on software—especially for taxpayers with international reporting obligations.
Pre-Immigration Tax Planning: What You Need to Know Before Moving to the United States
If you're planning to move to the United States, there’s more to think about than booking flights and finding a new home. One of the most important — and most overlooked — parts of the transition is your financial and tax planning.
Protecting Attorney-Client Privilege in IRS Streamlined Filing Compliance Submissions: The Role of Kovel Agreements
The IRS Streamlined Filing Compliance Procedures (which includes the Streamlined Domestic Offshore Procedures and the Streamlined Foreign Offshore Procedures) offer a critical path to compliance for taxpayers who failed to report foreign financial assets but whose conduct was non-willful. While these procedures provide relief from certain penalties, the decision to come forward is often accompanied by sensitive discussions about intent, omissions, and timing—issues that could be pivotal if the IRS challenges the non-willfulness assertion. This raises an essential question: how do we protect those communications during the disclosure process?
Part II: An In-Depth Analysis of U.S. Tax Implications for Usufruct Arrangements
Estate planning in many civil law jurisdictions often involves splitting full property ownership into two distinct parts: the right to use and enjoy the property (the usufruct) and the underlying legal title (the bare ownership). Although this method serves both tax and non‐tax objectives abroad, it poses unique challenges under U.S. tax law, where there is no direct counterpart to these civil law concepts. U.S. tax authorities therefore frequently draw analogies—comparing the arrangement to gifts of future interests, testamentary bequests, foreign trusts, or even joint tenancies—to determine its tax treatment.
