Feature Article

How I Got Into Tax and Why I Love It

When I was in high school, my 11th-grade English teacher noticed that I wrote really well and loved to read, but I was getting a D in her class. She determined that I was bored and wasn’t being challenged. So, I was moved to Honors English. My first day in Honors English we were given the assignment to write a short story. At the time, I was reading a lot of Clive Barker novels, and I wrote a 25-page story called “Meat Loc... Craig W. Smalley, EA

Capitol Corner

Setting the Stage for 2018

While 2017 was quite the roadshow spectacle in terms of the smattering of challenges and events enrolled agents encountered and should remember for years to come, NAEA continues to stand tall on behalf of the EA profession while powering its members. As you navigate the maze of a busy fling season, Congress is ramping up its efforts to reform the Service with a newly appointed commissioner (NAEA believes a successor will b... Justin Edwards

Feature Article

Undisclosed Foreign Accounts: Protecting the Executor

An executor administering an estate with undisclosed foreign accounts is exposed to substantial risks that may not be apparent. The following discussion is intended for executors and administrators who wish to understand and avoid those risks.1 A Typical Scenario A taxpayer dies. An executor is appointed and learns of foreign accounts: Tose foreign accounts hold investments. The ... Frank Agostino, Esq., Nicholas R. Karp, EA, USTCP

Tax Court

Does a Tax Treaty Govern the Taxability of Unemployment Compensation?

Pei Fang Guo, Petitioner v. Commissioner of Internal Revenue, Respondent 149 T.C. No. 14 Filed October 2, 2017 By Steven R. Diamond, CPA The United States has income tax treaties with many foreign countries. These treaties provide that residents of foreign countries may be taxed at a lower rate or may be exe... Steven R. Diamond, CPA

Feature Article

Taxation of Dividends From Foreign Corporations

U.S. persons frequently own legal entities abroad to pursue a variety of economic interests. Common U.S. ownership scenarios include expatriates forming foreign entities to locally operate businesses, U.S. residents forming foreign entities to capitalize on expansion opportunities, and entrepreneurial immigrants coming to the U.S. More often than not, these foreign entities default to corporate status à la the tax law’s default classification... Anthony (“Tony”) Malik, EA