Source: The Efm Law Company Blog

The Efm Law Company Blog Foreign Tax Home & Bona Fide Foreign Residence Established

Where Lock and Acone fell short, Linde v. IRS, T.C. Memo 2017-180 succeeded in establishing a foreign tax home. Therein, the Tax Court provided this analysis:"Section 911(d)(3) defines the term “tax home” as an individual’s home for purposes of section 162(a)(2). Section 162(a)(2) provides for a deduction for ordinary and necessary expenses paid during the taxable year in carrying on a trade or business, including travel expenses incurred while away from home in the pur [...]

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$100K-5.0M
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