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.
The One Big, Beautiful Bill: What the 2025 Tax Reform Means for Businesses, Employees, and Investors
The U.S. House of Representatives has passed the “One Big, Beautiful Bill”, a sweeping 2025 tax reform package that redefines the U.S. tax landscape. From new business deductions to expanded health savings account (HSA) eligibility and revised international tax enforcement, this bill has major implications for businesses, employees, and investors.
Part I: A Primer on Usufructs and Their Treatment by the IRS
Explore the legal implications of usufruct, a civil law property right, and how the IRS treats it in cross-border tax and estate planning.
FBAR UPDATE: The Sixth Circuit Rules Willfulness Includes Recklessness - March 2024
Under the Bank Secrecy Act, individuals with foreign bank accounts containing an aggregate of $10,000 or more must annually file a Report of Foreign Bank and Financial Accounts (“FBAR”) with the U.S. Department of the Treasury. An individual who fails to file an FBAR by the deadline risks civil penalties.
Corporate Transparency Act Update: Unenforceable Against Only Certain Businesses
In 2021, Congress enacted the Corporate Transparency Act (“CTA”) as part of an anti-money-laundering initiative. The CTA mandates that all entities formed or registered to do business in the US (“Reporting Companies”) and all foreign entities registered to do business in any state, unless exempt, must disclose their beneficial ownership to the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”).
AmCham Peru Renews Its Members For The Period 2024-2025
Carlos F. Concepción has been renewed as a member of The Arbitration Court of the International Arbitration Center of the American Chamber of Commerce of Peru for 2024-2025.