International investing can provide diversification and access to global markets, but U.S. taxpayers must understand the regulatory and tax compliance obligations that accompany offshore holdings. The challenges of offshore investments often arise not from the investments themselves, but from the complex reporting requirements imposed under U.S. tax law. Failure to...
IRS Audits Are Fewer in Number but Increasingly Aggressive
The agency itself recently stated IRS audits are fewer in number but increasingly aggressive based upon the "decrease in resources available for examinations." AI has become the agency's primary tool to identify tax return anomalies, errors, and omissions, and target appropriate taxpayers for closer examination and/or audit. Key Takeaways From...
Offshore Real Estate Ownership and Tax Reporting Requirements
What do you need to know about offshore real estate ownership and any associated tax reporting requirements? Are you a U.S. taxpayer or U.S. resident who owns real estate outside of the United States? It may surprise you to learn that the U.S. and many individual states, including California and...
Could an Upcoming Supreme Court Case Significantly Change US Tax Law?
Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus “unrealized” income, and the repatriation of accumulated foreign earnings. The stakes could not be higher. Realized...




