Engineer cannot escape closing agreement
A taxpayer cannot the avoid consequences of a closing agreement.
Expatriates
Foreign earned income exclusion: Pandemic-related relief
The IRS provides relief for taxpayers who would have qualified for the foreign earned income exclusion in 2019 and 2020 but for COVID-19.
Puerto Rico residents: Scope of income tax exemption for capital gains
The tax advantages available in Puerto Rico have recently captured the interest of both taxpayers and the IRS.
Tax treaties do not provide a foreign tax credit against net investment income tax
A U.S. taxpayer living abroad was not entitled to take a foreign tax credit against her net investment income tax based on provisions in the United States–France and United States–Italy tax treaties.
Unintended consequences of foreign branch reporting
Certain U.S. citizens and U.S. residents doing business abroad can have surprising tax reporting obligations as a consequence of the IRS's revised instructions to Form 8858.
