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  • Article

    IRS’s Voluntary Disclosure Program for Offshore Accounts: A Critical Assessment After One Year - Part 1

    Exactly one year ago, the tax world watched as the Internal Revenue Service conducted what may have been the most extraordinarily successful tax compliance feat in American history.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Technology Transfer and the New Economy

    The presidential debates put in sharp relief the challenges facing the United States economy regarding rising deficits, underfunded liabilities for Social Security, Medicare, and health care. Outsourcing of jobs has created dislocations and job losses and lessening of employment opportunities throughout the United States and particularly in the economically depressed areas that once were the engines of our economy that fueled our quality of life.
    United StatesStrategy
Caplin & Drysdale, Chartered
Caplin & Drysdale, Chartered
  • Article

    Time For A Change: Toward A New Korea-U.S. Income Tax Treaty

    The United States has 66 bilateral income tax treaties in place. Under these treaties, residents (not necessarily citizens) of foreign countries are generally taxed at a reduced rate or are exempt from U.S. tax on some items of income they receive from sources within the United States.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Sound And Fury, Signifying What? The U.S. Foreign Earned Income Exclusion Debate

    Congress possesses the constitutional authority to tax American citizens on their worldwide income.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Foreign Trust Reporting And Compliance - Part 1

    The United States generally imposes an income tax filing requirement on all U.S. persons and certain foreign persons, including certain foreign trusts with U.S. owners or other U.S. nexus.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Foreign Trust Reporting And Compliance, Part Two

    The United States generally imposes an income tax filing requirement on all U.S. persons and certain foreign persons, including certain foreign trusts with U.S. owners or other U.S. nexus.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Before It's Too Late: Reconsidering The IRS Relief For Madoff Losses

    In this article Richard W. Skillman analyzes the tax treatment of previously reported phantom income from a Ponzi scheme and concludes that the IRS had no legal basis to deny the applicability of section 1341.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
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