Can Trump Revive The Revenge Tax By Executive Order ? OECD Delays Test G7 Deal

On May 22, as the House of Representatives passed H.R. 1—the "One Big Beautiful Bill Act" (OBBBA)—by a 215-214 margin, I outlined the implications of Section 112029 of H.R.1 in my earlier Forbes article. The provision, "Enforcement of Remedies Against Unfair Foreign Taxes,” would have added a new Section 899 to the Internal Revenue Code. As … Continue reading Can Trump Revive The Revenge Tax By Executive Order ? OECD Delays Test G7 Deal →

“Revenge Tax” is Scrapped From The One Big Beautiful Bill

BREAKING NEWS --- On June 26, 2025, Treasury Secretary Scott Bessent announced a "deal" between the US and the G7 nations (Canada, France, Germany, Italy, Japan, and the UK) to exempt US companies from certain foreign taxes, prompting him to request Congress to drop proposed new Internal Revenue Code Section 899 from the One Big … Continue reading “Revenge Tax” is Scrapped From The One Big Beautiful Bill →

Tax Challenges: Foreign Owned U.S. Real Estate Via Single-Member LLC

For some time, foreigners have been drawn to the U.S. real estate market due to its stability, potential for appreciation, and the reliable legal framework in America. A frequently used investment vehicle is a single-member limited liability company created under the laws of a U.S. state. A SMLLC offers liability protection and flexibility. The U.S. … Continue reading Tax Challenges: Foreign Owned U.S. Real Estate Via Single-Member LLC →

Taxation Of Stock Options For Foreign Nationals Working In The U.S.

Many foreign persons are employed in America and are given stock options as an incentive by the companies for which they work. When a foreign national works in the U.S. and is granted stock options, the taxation of these options can become complex, especially if the individual later leaves the U.S. and becomes a nonresident alien … Continue reading Taxation Of Stock Options For Foreign Nationals Working In The U.S. →

Insights For Foreigners: Navigating The U.S. Tax Maze Before Residency

As some of my readers know, I am now a contributor writing on Forbes. My coverage area is US international tax law for overseas Americans and foreigners. My article is copied below. It first appeared on Forbes April 14, 2024 here. Don't miss out on my informative and easy-to-understand US tax content - Follow me … Continue reading Insights For Foreigners: Navigating The U.S. Tax Maze Before Residency →

Corporate Transparency Act: BEWARE! The Scammers have Already Arrived!

As most of my readers know the Corporate Transparency Act (CTA) requires US entities (including for example, US LLCs, corporations, partnerships), and many foreign entities including those that register to do business in a state, to disclose to FinCEN of the Treasury Department, the identity of their beneficial owners. Information to be provided: name, date … Continue reading Corporate Transparency Act: BEWARE! The Scammers have Already Arrived! →

Corporate Transparency Act – Unconstitutional, But Keep Reporting!

My earlier blog post discussed National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.), the Northern District Court of Alabama decision that enjoined all relevant US government agencies from enforcing the Corporate Transparency Act (CTA). That post raised the issue: exactly who is entitled to the benefits of this injunction? Well, let's look carefully … Continue reading Corporate Transparency Act – Unconstitutional, But Keep Reporting! →

Corporate Transparency Act Declared Unconstitutional

With this surprising court decision issued March 1, 2024, millions of overwhelmed small business owners can now take a breather from scouring FinCEN’s website and go back to running their businesses. The Northern District Court of Alabama has enjoined all relevant US government agencies from enforcing the Corporate Transparency Act (CTA). The UNITED STATES DISTRICT … Continue reading Corporate Transparency Act Declared Unconstitutional →

US Estate Tax: Location of Assets, More “Situs” Rules

Part I of this blog post examined some of the rules regarding the US estate tax and how it applies to non-US persons (noncitizen/nonresident - based on the concept of "domicile"). Unfortunately, the US estate tax often catches the non-US citizen non-domiciliary's family by surprise and when it does, it bites hard. Remember, the non-US citizen … Continue reading US Estate Tax: Location of Assets, More “Situs” Rules →

Foreign Partnerships with a US Partner? Some Planning Ideas

An earlier blog post explained how easy it is for the foreign person to fall into some nasty US tax traps when entering a foreign partnership with a US person. Even if that foreigner never sets foot in America and works solely from the foreign location, he can end up paying US taxes. In addition, … Continue reading Foreign Partnerships with a US Partner? Some Planning Ideas →