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International Tax Blog

Andrew Mitchel LLC is a law firm of international tax attorneys with extensive experience in international tax planning.

2017 Second Quarter Published Expatriates – Second Highest Ever

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2017.

The number of published expatriates for the quarter was 1,759, which is the second highest quarterly number ever (second only to the fourth quarter of 2016 which had 2,365 published expatriates).  The number of published expatriates for the first two quarters of 2017 has been 3,072 (1,313 + 1,759).  In the first two quarters of 2017, there has already been more published expatriates than there was for the entire year of 2013 (2,999), which was the first year of explosive growth in the number of published expatriates.

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Tax Court Declines To Follow Rev. Rul. 91-32

Last week, the Tax Court released an important opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, where the court declined to follow Rev. Rul. 91-32.

For more than 25 years the IRS has maintained that gain on a foreign partner’s disposition of an interest in a partnership that conducts business in the U.S.… Read more

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An Unsubstantiated Presumption

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today’s tax quote is:

The tax collector’s presumption of correctness has a herculean muscularity of Goliathlike reach, but we strike an Achilles’ heel when we find no muscles, no tendons, no ligaments of fact.

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Failures To Adjust For Inflation

If Congress pursues tax reform this year, it should consider allowing inflation adjustments for the items discussed below. 

Each year, the IRS publishes inflation adjustments that modify the tax law as originally enacted.  We regularly post about the inflation adjustments in the international tax arena.  However, there are some significant values in the international tax area that are not adjusted for inflation.  In one case, the value has remained unchanged for over eighty years.Read more

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U.S. Government Continues To Pursue Taxpayers Committing Tax Fraud

As we have reported in past years the U.S. government actively pursues taxpayers that are committing tax fraud.  The Justice Department publicizes its successes in its press releases.  The press releases continue to demonstrate an impressive list of tax-related convictions, guilty pleas, injunctions, summonses, and other actions against taxpayers (and tax preparers).  Many of the tax fraud schemes include offshore activities.

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5 New Tax Charts

Today we added 5 new situational charts to andrewmitchel.com dealing with Section 987 Branch Transactions.

  • Reg. 1.987-1(b)(7), Example 1 (Not a Section 987 QBU: Disregarded Entity Holding Stock & Servicing a Debt)
  • Reg. 1.987-1(b)(7), Example 2 (Section 987 QBU: Disregarded Entities with Active Businesses)
  • Reg.
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