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Foreign income exlcusion

District Court -IRS incorrectly disallowed foreign tax credit and foreign earned income exclusion

District Court -IRS incorrectly disallowed foreign tax credit and foreign earned income exclusion

Estate of Herrick (DC UT 3/25/2016) 117 AFTR 2d ¶ 2016-555 A district court has held that a taxpayer provided sufficient evidence of his foreign tax liability to have that liability taken into consideration for purposes of the foreign tax credit (FTC) and that he timely elected the foreign earned income exclusion (FEIE). As a […]

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Residency and presence tests for 2015 foreign income/housing exclusions waived for Burundi

Residency and presence tests for 2015 foreign income/housing exclusions waived for Burundi

Rev Proc 2016-21, 2016-14 IRB In a Revenue Procedure, IRS has waived the residency and presence tests that apply for purposes of the Code Sec. 911 foreign earned income and foreign housing cost exclusions with respect to certain U.S. individuals in Burundi due to adverse conditions in that country beginning on May 14, 2015. Background. Code […]

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Reporting Foreign Income: Eight Tax Tips from the IRS

Reporting Foreign Income: Eight Tax Tips from the IRS

Reporting Foreign Income: Eight Tax Tips from the IRS Did you receive income from a foreign source in 2015? Are you a U.S. citizen or resident who worked abroad last year? If you answered ‘yes’ to either of those questions, here are eight tips to keep in mind about foreign income: 1. Report Worldwide Income. By law, […]

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Regs on withholding where foreign person disposes of USRPI reflect Path Act changes

Regs on withholding where foreign person disposes of USRPI reflect Path Act changes

TD 9751: PATH Act Changes to Section 1445. IRS has issued final and temporary regs on the taxation of, and withholding on, foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests (USRPIs); the regs reflect changes made by the Protecting Americans from Tax Hikes Act of 2015 (the PATH […]

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Tax Court – previous IRS auditor saying taxpayer wasn’t employee didn’t affect tax but eliminated penalty

Tax Court – previous IRS auditor saying taxpayer wasn’t employee didn’t affect tax but eliminated penalty

Alfred S. Co, TC Memo 2016-19 The Tax Court has held that a taxpayer who worked under a series of personal service contracts for the U.S. Department of State was an employee of the U.S. government and thus the income he earned in the position was not foreign earned income under Code Sec. 911(a). The […]

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Tax Court – No foreign income exclusion for civilian assigned by U.S. Army to NATO

Tax Court – No foreign income exclusion for civilian assigned by U.S. Army to NATO

Striker, TC Memo 2015-248 The Tax Court has held that a civilian who was hired, paid, and subject to discipline by the U.S. Army was an employee of the U.S. and thus not qualified for the foreign earned income exclusion, despite the fact that all of his duties were part of a North American Treaty […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney