Feature Articles | EA Journal

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

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

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

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

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