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Cross-Border Debt in the Post-BEPS World: Interest Limits, Hybrids, and Earnings Stripping
By Anthony N. Verni, Attorney at Law, CPA Series: International Tax Reform 2025 – Part…
Intangibles and the Digital Economy: Transfer Pricing in the Shadow of Pillar Two
By Anthony N. Verni, Attorney at Law, CPA Series: International Tax Reform 2025 – Part…
Tax Treaties in a Fractured World: Pillar Two, U.S. Non-Participation, and What It Means for Multinationals
By Anthony N. Verni, Attorney at Law, CPA Series: International Tax Reform 2025 – Part…
CFCs, High-Tax Exceptions, and the End of Easy Deferral
By Anthony N. Verni, Attorney at Law, CPA Series: International Tax Reform 2025 – Part…
Modern Foreign Tax Credit Planning: Baskets, Blending, and BEPS-Era Risks
By Anthony N. Verni, Attorney at Law, CPA Series: International Tax Reform 2025 – Part…
GILTI and FDII After a Decade: What U.S. Multinationals Must Re-Evaluate in 2025
By Anthony N. Verni, Attorney at Law, CPA Series: International Tax Reform 2025 – Part…
IRS Audits for Foreign Income: Triggers and Defense Strategies
When you earn money outside the United States, it can honestly feel like you’re living…
How to Remove a Federal Tax Lien or Levy: Rights, Deadlines, and Remedies
A tax lien or levy is not a spontaneous incident; it is a result of…
Pending ERC Litigation and the Administrative Procedure Act: IRS Reliance on FAQs and Notices Instead of Regulations
Prepared by Anthony N. Verni, Attorney at Law, CPA The Employee Retention Credit (“ERC”), enacted…
Evolving FBAR Enforcement: Are International Efforts Keeping Pace with Modern Offshore Concealment Techniques?
Introduction The Report of Foreign Bank and Financial Accounts (“FBAR”) requirement, mandated under 31 U.S.C.…
IRS Coming After You? Why a Tax Attorney for Back Taxes Is Your Best
Back taxes don’t usually land in one big shock; they drag up over time. Maybe…
Russian Pensions, FBAR Reporting, and the Suspension of the U.S.–Russia Tax Treaty
Introduction The U.S. government’s suspension of the U.S.–Russia Income Tax Convention, effective 2024, has created…