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Why the Glenshaw Glass Test for Income Is Total Crap and Federal Courts just do whatever they want.

Introduction: Understanding the Glenshaw Glass Test and Its Origins The Glenshaw Glass Test emerged from a landmark Supreme Court decision in Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955). This pivotal case defined the parameters of “income” under the Internal Revenue Code, specifically focusing on the inclusion of certain types of gains that were […]

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Can the IRS Exit Tax be retroactive? Does IRC Section 877A go back in time?

Understanding the Basics of the IRS Exit Tax The IRS Exit Tax, officially governed by Internal Revenue Code (IRC) Section 877A, applies to U.S. citizens and certain green card holders who choose to expatriate. Expatriation, in this context, refers to the formal process of renouncing U.S. citizenship or abandoning lawful permanent resident status after meeting

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How To Find A Tax Professional For International, Foreign, And Expat Tax Issues

Understanding the Complexities of International, Foreign, and Expat Taxes Navigating international, foreign, and expat taxes requires a thorough understanding of tax laws and regulations across multiple jurisdictions. Unlike domestic tax situations, these areas involve overlapping rules, treaties, and reporting requirements that can vary significantly between countries. Taxpayers who have income or assets abroad, dual citizenship,

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Five Keys To Avoiding An IRS Audit | Red Flags & Reverse Red Flags for 2025

Understanding the IRS Audit Process: What Triggers an Audit? The IRS audit process is a highly meticulous procedure aimed at ensuring taxpayer compliance with federal tax laws. While audits are not exceedingly common, certain factors can increase the likelihood of triggering one. Knowing these triggers can be essential for taxpayers who wish to stay within

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Unfiled Taxes? How to Use IRS Streamlined Procedures for Compliance

Understanding the Importance of Filing Tax Returns Filing tax returns is not only a legal requirement but also a critical step in maintaining financial and legal credibility. When individuals or businesses fail to file, they risk potential penalties, repercussions, and lost benefits. Understanding why filing on time is essential can help taxpayers avoid complications with

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Put America first by putting Americans first. End global taxation and compliance bloat

The Concept of ‘America First’: What Does It Truly Mean? The phrase “America First” traces back to movements advocating national priorities as a foundation for policymaking. It conveys the idea that the country’s interests, productivity, and citizen well-being should be fundamental in shaping economic, social, and political frameworks. At its core, this concept emphasizes prioritizing

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IRS Streamlined Disclosures: What happens when you DON’T make one?

Understanding IRS Streamlined Disclosures: An Overview The IRS Streamlined Filing Compliance Procedures are designed to help taxpayers who have failed to report foreign income, assets, or accounts and must rectify their situation without facing severe penalties. These procedures primarily target individuals who can certify that their noncompliance was non-willful, meaning the failure was due to

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How Far Back Must You File Unfiled Tax Returns? | IRSMedic

Understanding the Importance of Filing Tax Returns Filing tax returns is not only a legal requirement but also a critical step in maintaining financial and legal credibility. When individuals or businesses fail to file, they risk potential penalties, repercussions, and lost benefits. Understanding why filing on time is essential can help taxpayers avoid complications with

How Far Back Must You File Unfiled Tax Returns? | IRSMedic Read More »

PFICs, FinCEN Crackdowns, and Social Security’s Future | IRSMedic March 20, 2025 Podcast

The Mysterious World of PFICs: Why They Matter Now More Than Ever The term “PFIC” might sound arcane, but behind this acronym lies a concept that has grown into a pivotal issue for those navigating the intersection of international investments and U.S. tax obligations. A Passive Foreign Investment Company, or PFIC, refers to a foreign

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