Blogs
Introduction to Work Visas and Their Impact
Every year, thousands of people want to start a career in the United States. Some…
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.…