By: Amanda Wilson If you are a foreign citizen that is considered to be a resident for U.S. income tax purposes, you need to be aware that your U.S. tax filing obligation is not limited to the income tax return. U.S. taxpayers (including foreign...

By: Amanda Wilson As I discussed in a prior blog post (found here), if you have more than $10,000 in a foreign bank account, you are obligated to file Form 114 (commonly known as an FBAR). Failure to make this filing can result in significant civil...

I will be participating in an webinar on June 11 addressing partnership allocations. If you are interested, information regarding the webinar can be found here.

By: Amanda Wilson The IRS has released yet another private letter ruling (Letter 201522002) in the REIT area. This time, the IRS addressed the REIT treatment of income from the rental of outdoor advertising space (i.e., billboards). At issue were...