Short Summary: Michelle Goddard (now DelPonte) filed joint income tax returns with her then-husband, William Goddard, a tax attorney.

For years, there has been a longstanding question under the subpart F rules on whether a controlled foreign corporation's ("CFC") mid-year earnings could be taken into account...

A taxpayer with shares in a passive foreign investment company (a "PFIC") may qualify to make either a qualified electing fund ("QEF") election or an election to...

On March 1, 2022, the IRS published its 128-page Exempt Organizations Technical Guide TG 58 Excise Taxes on Self-Dealing under IRC 4941.

The tax issues involved in the 2014 and 2015 tax returns regarded Amos's carryforward— under 26 U.S.C. § 172—of NOLs relating to the Fuddruckers enterprise dating back to about 1999.

A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. Payments of U.S.-source "fixed and determinable annual or periodic...

Sales tax . . . A (if not the most) commonly overlooked tax for nonprofit organizations. This Freeman Law Insights blog focuses on sales tax regime applicable to "admissions" collected...

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Through over 15 years of representing nonprofit organizations, one thing is for certain–there are infinite exempt purposes that may be served within the confines of section 501(c)(3) of the...

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Summary: Edgerton Mighty and Eulalee Mighty (together, Mighty) sought review of the determination by the IRS to uphold the filing of a Notice of Federal Tax Lien for 2014.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Generally, income from the sale of personal property is "sourced" to the residence of the seller. If the seller is a U.S. tax resident the source of the income is deemed to be the United States.

Missing any deadline is stressful. But missing a tax deadline is more so. Per the Bank Secrecy Act (Title 31 of the U.S. Code), certain taxpayers must file so-called FBARs (currently FinCEN Form 114)...

Entity "A" is a corporation from country A and is the parent company of a global group. "A" owns all the stock of Corporation "B". "A" and "B" own all the outstanding stock of Distributing.