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

Understanding the IRS Exit Tax: An Overview The IRS Exit Tax, primarily governed by IRC Section 877A, applies to certain individuals who formally expatriate from the United States by renouncing their U.S. citizenship or ending their status as long-term residents. This tax provision targets individuals deemed “covered expatriates” based on specific criteria, including income thresholds, […]

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Tax consequences of an expired (or not) US Green Card: The Twilight Zone Edition

Understanding the US Green Card: Its Benefits and Obligations A US Green Card, formally known as a Permanent Resident Card, is an essential document for immigrants seeking long-term residency and employment in the United States. It grants holders lawful permanent resident (LPR) status, opening the door to a range of rights and privileges, as well

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Is the IRS logo satanic? If Not, Then Why Is There An Upside Down Cross In The IRS Logo?

Introduction: The Controversy Surrounding the IRS Logo The logo of the Internal Revenue Service (IRS), the federal agency responsible for tax collection and enforcement in the United States, has sparked debates and controversies in various circles. Specifically, some individuals claim an unusual feature within the logo hints at hidden symbolism. At the center of this

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IRSMedic has job openings for the best US tax professionals around the globe!

Introduction to IRSMedic: Transforming Tax Representation IRSMedic has carved a unique niche in the complex world of tax representation, offering a fresh approach to resolving tax issues and disputes. With a focus on unparalleled client advocacy, the firm has established itself as a beacon of support for individuals and businesses confronted by IRS challenges. Recognized

IRSMedic has job openings for the best US tax professionals around the globe! Read More »

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

Introduction: The Origins and Significance of the Glenshaw Glass Test The Glenshaw Glass Test derives its origins from the landmark Supreme Court case, Commissioner v. Glenshaw Glass Co., 348 U.S. 426 (1955). This decision served as a pivotal moment in federal tax law by explicitly defining gross income under Section 61 of the Internal Revenue

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Will This Black American Woman Be Forced To Renounce US Citizenship?

Introduction: Exploring Citizenship Dilemmas in Modern America Citizenship has become a cornerstone of personal identity and societal engagement, particularly in a nation as diverse and complex as the United States. For centuries, the concept of American citizenship has defined what it means to belong, offering individuals certain rights, protections, and opportunities while also imposing responsibilities.

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FATCA 2021 Updates: Expats, Renunciation, Recap of call with Rep. Carolyn Maloney

Introduction to FATCA: Overview and Key Objectives The Foreign Account Tax Compliance Act (FATCA) is a U.S. federal law aimed at combating tax evasion by U.S. persons holding financial assets abroad. Enacted as part of the Hiring Incentives to Restore Employment (HIRE) Act in 2010, FATCA introduced comprehensive requirements for foreign financial institutions (FFIs) and

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Fed up with FATCA, FBAR, GILTI. etc? Take this SEAT – Stop Extraterritorial American Taxation!

Understanding the Challenges: FATCA, FBAR, and GILTI Explained The complexities of U.S. tax requirements for Americans living abroad have led to widespread confusion and frustration. Key among these challenges are the Foreign Account Tax Compliance Act (FATCA), the Foreign Bank Account Report (FBAR), and the Global Intangible Low-Taxed Income (GILTI) tax provisions. Each represents a

Fed up with FATCA, FBAR, GILTI. etc? Take this SEAT – Stop Extraterritorial American Taxation! Read More »

US District Court Welcome’s IRS new Sec 965 wealth tax. Inside the horrible decision of Moore v. US

Introduction to the IRS Section 965 Wealth Tax The IRS Section 965 tax provision, introduced as part of the Tax Cuts and Jobs Act (TCJA) of 2017, represents a pivotal shift in the taxation of income accumulated by foreign corporations. Commonly referred to as the “transition tax” or associated with terminology like wealth tax in

US District Court Welcome’s IRS new Sec 965 wealth tax. Inside the horrible decision of Moore v. US Read More »

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