A quarterly magazine from the National Association of Enrolled Agents
Spring 2025 vol.43 no.1
NAEA Advocacy 2025: Opportunities, Challenges, and Unfinished Business
Capitol Corner

NAEA Advocacy 2025: Opportunities, Challenges, and Unfinished Business

2025 will bring several opportunities and challenges for National Association of Enrolled Agents (NAEA) advocacy with the new 119th Congress and the Trump administration. Flashback eight years to December 2017 at the dawn of... Michelle McCaughey, Thad Inge, and Samantha Ford

Spring 2025, Capitol Corner, advocacy
The EA Journal Is an Example of Excellence
EVP Message

The EA Journal Is an Example of Excellence

I want to take this time to direct you back to page 3 and review the list of names in the masthead and join me in giving a huge shout out to the incredibly talented team that creates the EA Journal. It’s a Herculean task, and without the efforts of our managing editor, edit...

Spring 2025, EVP Message, practice management
Anisha Bailey, EA
Member Profile

Anisha Bailey, EA

Where do you reside? Cincinnati, Ohio area What got you involved in the tax profession? In 2006, with the goal of becoming a certified professional accountant (CPA), I decided to go back to school for accounting because... Anisha Bailey, EA

Spring 2025, Member Profile, practice management
United States International Tax Treaties: A Guide for Early Career Tax Professionals
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
Staying Afloat in the Rising Tide of Foreign Bank Account Reporting
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

Spring 2025, Feature Article, Financial Crimes Enforcement Network, FinCEN, Foreign Account Tax Compliance Act, FATCA, Form 1040, PATRIOT Act, Bank Secrecy Act, Foreign Bank Account Reporting, FinCEN Form 114, Schedule B, IRS Publication 5569, BSA E-Filing System
Dealing with Negative Reviews on Social Media: A Balanced Approach for Tax Professionals
Tax Tech

Dealing with Negative Reviews on Social Media: A Balanced Approach for Tax Professionals

In today’s digital age, online reviews are more than just feedback—they are a form of validation that can deeply affect us, both professionally and personally. Recently, a client walked into my office, and when I as... Jose Delgado, EA, NTPI Fellow®

Spring 2025, Tax Tech, technology, CP2000, practice management, Social media
Do Disproportionate Distributions Terminate an S Corporation Election?
Tax Court

Do Disproportionate Distributions Terminate an S Corporation Election?

S corporations cannot have more than one class of stock.i Based on this prohibition, many tax professionals believe that an S corporation that makes disproportionate distributions to shareholders terminates its S corporation e... Thomas A. Gorczynski, EA, USTCP

Spring 2025, Tax Court, s corporation, c corporation, Tax Court, Form 1040, stock, §1362(d)(2), Maggard and Chang, disproportionate distributions, shareholders, private letter ruling, liquidation
Cost Allocation Base Selection for Transfer Pricing Purposes
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

Spring 2025, Feature Article, basis, transfer pricing, Treasury Regulation §1.482-9, cost allocation, §482
FBARS, Treaties, and Tax—Oh My!
Editor's Message

FBARS, Treaties, and Tax—Oh My!

As tax professionals, we often focus on familiar territory, honing in on our areas of expertise. However, clients may occasionally present us with unfamiliar, complex issues, particularly in the realm of international tax. Given the significant penalties for noncomplianc... Tynisa (Ty) Gaines, EA (She/Her)

Spring 2025, Editor's Message, s corporation, FBAR, international, practice management, Foreign Bank Account Reporting, Federal Trade Commission, FTC, transfer pricing, mixed-status
Promoting and Mentoring the Next Generation of Enrolled Agents
Practice Builder

Promoting and Mentoring the Next Generation of Enrolled Agents

We have all been “newbies” at some point—whether it was learning about enrolled agents (EAs), preparing for the Internal Revenue Service (IRS) Special Enrollment Examination (SEE), starting a new career, or launc... Beth Logan, EA

Spring 2025, Practice Builder, practice management, mentor
Let’s Be Bigger and Better Together
President's Message

Let’s Be Bigger and Better Together

This is my final EA Journal column as president of the National Association of Enrolled Agents (NAEA). Serving as your president has been a very fulfilling experience in my professional career. I am honored to have had the opportunity to serve such a wonderful community ... Twila Midwood, EA

Spring 2025, President's Message, advocacy, practice management
Unmasking the Myths: Who Can Truly Be a Shareholder in an S Corporation?
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
Tax Complexities for Mixed-status Families
Preparation

Tax Complexities for Mixed-status Families

America: The bold, the beautiful, the ultimate melting pot, where people from all over the world come in search of opportunity, freedom, and the American dream. In their pursuit of a better life in this great country, immigrants may grow t... Brittany Sabalza, EA

Spring 2025, Preparation, TCJA, Tax Cuts and Jobs Act, immigrants, COVID-19, CARES Act, Social Security, EIC, additional child tax credit, ACTC, CTC, child tax credit, ITIN, individual taxpayer identification number, SSN, undocumented, mixed-status, §32(c)(1)(E), earned income credit, Center on Budget and Policy Priorities, CBPP
Understanding FTC Regulations on Advertising and Endorsements
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

Spring 2025, Feature Article, AI, practice management, Social media, Artificial intelligence, advertising, Federal Trade Commission, FTC, endorsement