Entries by Manager

Employee Stock Option Sourcing Rules | International Tax Lawyer & Attorney

Employee stock option sourcing rules govern the US tax classification of income generated by stock options as US-source income or foreign-source income. In this article, I will provide a general overview of the employee stock option sourcing rules. Employee Stock Option Sourcing Rules: Importance of Income Sourcing Rules Income sourcing rules are very important in […]

September 2018 IRS Compliance Campaigns | International Tax Lawyer & Attorney News

On September 10, 2018, the IRS Large Business and International division (“LB&I”) announced the creation of another five compliance campaigns. Let’s explore in more depth these September 2018 IRS Compliance Campaigns. September 2018 IRS Compliance Campaigns: Background Information Since January of 2017, the IRS has been regularly adding more and more compliance campaigns. The compliance […]

July 2018 IRS Compliance Campaigns | International Tax Lawyer & Attorney

On July 2, 2018, the IRS announced the creation of another five compliance campaigns. Let’s discuss these July 2018 IRS Compliance Campaigns in more detail. July 2018 IRS Compliance Campaigns: Background Information The IRS compliance campaigns is the end result of a long period of planning by the IRS Large Business and International division (“LB&I”). […]

IRS Large Corporate Compliance Program | IRS Lawyer & Attorney

On May 16, 2019, the IRS Large Business and International Division (“LB&I”) announced the creation of a new compliance program for the large corporations – Large Corporate Compliance program. The Large Corporate Compliance program will cover the oversight of the LB&I’s largest corporate taxpayers. It replaces the existing Coordinated Industry Case program. The replacement of […]

May 2018 IRS Compliance Campaigns | International Tax Lawyer & Attorney

On May 21, 2018, the IRS announced the creation of another six compliance campaigns. Let’s explore these May 2018 IRS Compliance Campaigns in more detail. May 2018 IRS Compliance Campaigns: Background Information After a long period of planning, the IRS Large Business and International division (“LB&I”) finalized its new restructuring plan in 2017. Under the […]