Tax Complexities for Mixed-status Families
Immigrants may encounter certain tax complexities navigating the United States tax system.
Tax Court
Do disproportionate distributions terminate an S corporation election?
Tax Tech
In today’s digital age, online reviews are a form of validation that can deeply affect us, both professionally and personally.
2025 Call for Articles
EA Journal is accepting articles on a variety of topics.
Feature Article 
United States International Tax Treaties: A Guide for Early Career Tax Professionals
With increasing international trade and financial activities, United States taxpayers face the risk of double taxation, where two or more countries tax the same income. To mitigate this risk and foster international economic ... Sarah Eddie, EA
Spring 2025,
Feature Article,
international, foreign tax credit, FTC, tax treaty, permanent establishment rules, PE, Langroudi, Mehrdad Hamzeye v. Commissioner, Form 1040NR, US-Belgium Double Tax Treaty, specific anti-avoidance rules, general anti-avoidance rules, LOB, limitation on benefits clauses, GAAR, SAAR, pay-as-you-earn, PAYE
Feature Article
Staying Afloat in the Rising Tide of Foreign Bank Account Reporting
In recent years, the Internal Revenue Service (IRS) has intensified its enforcement efforts targeting noncompliance with foreign bank account reporting (FBAR)i requirements. This heightened focus has resulted in a significant increase in the ... Chelsea Rustek, EA
Feature Article
Cost Allocation Base Selection for Transfer Pricing Purposes
The successful implementation of a cost-based transfer pricing policy necessitates the group of companies to devise robust internal cost allocation methodologies. The reasonability of the cost ... Anthony (“Tony”) Malik
Feature Article
Unmasking the Myths: Who Can Truly Be a Shareholder in an S Corporation?
Revisiting the Basics of the S Corporation: Nonresidents as Shareholders Small business corporations are more popular than ever. You hear about them on social media, and among the tax community. Indeed, sm... Fernando Juarez, EA, and Edgar Gonzalez, EA
Spring 2025,
Feature Article,
TCJA, Tax Cuts and Jobs Act, s corporation, c corporation, GILTI, nonresident alien, ITIN, small business, partnerships, beneficiary, controlled foreign corporation, CFC, SSN, §1362(d)(2), shareholders, double taxation, foreign bank account, green card test, substantial presence test, Treas. Reg. 1.1361-1(g)(1)(i), §7701(b)(1)(B), §7701, Office of the Chief Administrative Hearing Officer, OCAHO, Immigration Reform and Control Act of 1986, Immigration Act of 1990, electing small business trust, ESBT, tax treaty, global intangible low-taxed income, Form 8833, Treas. Reg. §301.7701(b)-7, INTL-121-90, §1361(a)(1), §1361(b)(2)(C), §1362(a), Treas. Reg. §301.7701(b)-7(a)(4), §957, §552
Feature Article
Understanding FTC Regulations on Advertising and Endorsements
Implications for Tax Professionals We have all seen those commercials where a large corporation makes unrealistic claims about its product, leaving us scratching our heads and wanting to throw... Brad D. Messner, EA
Department Highlights
Editor's Message 
FBARS, Treaties, and Tax—Oh My!
Spring 2025, Editor's Message, s corporation, FBAR, international, practice management, Foreign Bank Account Reporting, Federal Trade Commission, FTC, transfer pricing, mixed-status
President's Message
Let’s Be Bigger and Better Together
Spring 2025, President's Message, advocacy, practice management
