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Marko Zivanov

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Treasury Issues Final FDII Regulations

FDII is foreign derived intangible income that a U.S. domestic corporation derives from selling products or providing services to unrelated foreign persons

Individuals Receive Information Reporting Relief for Transactions with Certain Foreign Trusts

Foreign trusts are subject to many tax filing requirements, and failure to meet them can result in significant penalties. Annual information reporting

Proposed Regulations Issued on Source of Income for Certain Sales of Personal Property

The Treasury Department and Internal Revenue Service recently released proposed regulations (REG-100956-19) that modify the rules for determining the source

IRS to Focus on Companies That Owe Taxes on Offshore Profits

The Internal Revenue Service recently announced it would focus on companies that owe taxes on overseas profits (a Section 965 tax, or as some call it,

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Reminder: Foreign-owned U.S. Disregarded Entities Face New Reporting Requirements

Until recently, disregarded entities (DREs) were typically not required to obtain an employer identification number (EIN) and generally did not have federal

IRS Issues Notice for Computing "Transition Tax"

On December 29, the Internal Revenue Service (IRS) and Treasury Department published Notice 2018-07 (Notice), providing guidance for computing the “transition

FinCEN Reminds Taxpayers of New FBAR Deadline

The Financial Crimes Enforcement Network (FinCEN) has reminded taxpayers that the due date for filing Reports of Foreign Bank and Financial Accounts (FBAR)

Taxation and Information Reporting for Foreign Trusts

The U.S. taxation and information reporting imposed on foreign trusts can be quite complex. A trust is the foreign trust if it is not the U.S. trust. A

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IRS Highlights Offshore Compliance Programs Achievements and Encourages Taxpayers to Enter the Programs

The IRS’s recent news release shows that the agency has passed several big milestones in moving forward with increasing compliance. Back in 2009,

Do You Have an Estate Plan for Digital Assets?

As digital presence of an individual continues to grow, the question of the digital assets estate planning is starting to emerge. There are obvious reasons

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