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Code Type R Visa: Comprehensive Guide for Religious Workers
Faith often calls people beyond borders to teach, to serve, or to build communities far…

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…