In a recent blog entitled, “US Automatic Exchange of Bank Information to 86 Foreign Countries in 2015,” Professor William Byrnes lists the countries with which
This is Part II of a two-part blog series. After establishing that they have a tax home in a foreign country, taxpayers must still establish
This blog addresses the foreign earned income exclusion rules as they apply to civilian contractors, and other civilian employees, who work in foreign country combat
The acquittal of Raoul Weil, the only Swiss banker to have prevailed over the U.S. government in an offshore tax evasion case, has become a
The IRS recently updated the list of foreign financial institutions that trigger an enhanced penalty in OVDP. While the offshore penalty is generally 27.5% of
In Part I, I argued that the benefits rationale – in terms of the public benefits received by citizens – was an unpersuasive justification for
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