Evolution of the Tax Home Concept as a Legal Term of Art*
Feature Article

Evolution of the Tax Home Concept as a Legal Term of Art*

Tax home is, particularly when considered in an international context, a curious legal term with a specific meaning that is at odds with what it superficially suggests. Counterintuitively enough, it does not patently mean the... Anthony (“Tony”) Malik, EA

Foreign Corporations, Form 5471, and the Perils of Offshore Noncompliance
Feature Article

Foreign Corporations, Form 5471, and the Perils of Offshore Noncompliance

Form 5471 is required to be filed by United States (U.S.) persons—citizens, resident aliens, domestic partnerships, and corporations, and certain estates and trusts—who are officers, directors, or 10... Manasa Nadig, EA

The Debate Between S Elections and C Elections: The Overlooked Case of Profit Projections
Feature Article

The Debate Between S Elections and C Elections: The Overlooked Case of Profit Projections

Few decisions in entity structuring spark more debate among tax practitioners than whether a closely held business should elect S corporation or C corporation treatment. Online forums, continuing educati... Elan Becker, EA

Caught Between Two Tax Systems: Practical Guidance on the U.S.–Italy Tax Treaty and Totalization Agreement
Feature Article

Caught Between Two Tax Systems: Practical Guidance on the U.S.–Italy Tax Treaty and Totalization Agreement

Practical Guidance on the U.S.–Italy Tax Treaty and Totalization Agreement Cross-border tax issues between the United States (U.S.) and Italy are increasingly common, especially amo... Luca Pizzale, EA, CPA

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