To read this article with full citations, please visit taxnotes.com Last week, Tax Notes International ran an insightful piece by Lewis J. Greenwald and Eric J. Rietveld, two attorneys with Sullivan & Worcester. The authors detail how the election of Pope Leo XIV, the first pope to hold U.S. citizenship, raises some novel concerns. The issues relate to the payment of U.S. federal income tax and compliance with U.S. information reporting requirements. Beyond the saving of souls, the new pope might need to worry about saving his receipts — in the event the IRS audits him. Their article argues, quite…

Todd and Julie Chrisley were convicted of tax evasion and bank fraud, and have been in prison since January 2023. Todd was sentenced to twelve years, and Julie was sentenced to seven years. But their long sentences ended when they were issued full pardons by President Trump. The President said he thought they had been treated harshly, but that is not unusual for the kind of bank fraud and tax evasion charges of which they were convicted. The Chrisleys may no longer need to worry about the big mistakes that landed them in jail, but there are still some big…

In 2022, Todd and Julie Chrisley were sentenced to prison for, among other things, tax fraud. The celebrity couple known best for their reality TV show titled “Chrisley Knows Best” became famous, in part, for their impression of living a lavish lifestyle. However, it was all a sham, which led to them being convicted of financial crimes. In unexpected news, President Trump has pardoned the Chrisleys. This article discusses their crimes, how what they did for tax evasion differs from legal tax avoidance, and what their pardoning might mean for tax enforcement during Trump’s second term. Todd and Julie Chrisley’s…

he United States has been a major destination for foreign direct investment for years. In 2022, foreign firms invested over $177 billion in the country. In May 2025, the U.S. House of Representatives passed the One Big Beautiful Bill Tax Act (OBB). Beyond the potential impact on foreign direct investment in the U.S. overall, certain provision of the OBB may have a broader impact, especially affecting common asset protection and wealth planning strategies. The increased rate on withholding, investments, corporate holdings, and more, is designed as a retaliatory measure on taxes, especially digital taxes, imposed by other countries which the…

T ina Turner’s death in May 2023 sparked an interesting consideration for the estates of expatriates. She relinquished her citizenship in late 2013, approximately ten years before her death and resided in Switzerland at her death. Despite being a noncitizen of the U.S. at her death, Turner may have been subject to U.S. income and estate taxes depending upon whether she was considered a covered expatriate and whether she had assets that would be considered U.S. assets taxable in her estate. The impact of the estate tax could deplete 40% of the assets subject to tax at her death. Given…

The season finale of Daredevil: Born Again referenced a fictional freeport in the Red Hook neighborhood of Brooklyn, New York which the villain, Kingpin was using to shield illicit assets from tax and tariffs. This nod in popular entertainment to a classic tax-efficiency strategy, especially for wealthy collectors of art, highlights the concern that freeports are also a breeding ground for illicit activities, such as money laundering. Unlike Foreign Asset Protection Trusts (FAPT), the use of freeports to limit tax exposure and obtain more security and privacy in the storage and transfer of luxury goods, such as fine art and…

Here’s something that you might not know about me: I once appeared on a reality television show. It wasn’t as exciting as “Survivor” or “Amazing Race”—there were no competitions, fabulous prizes, or tropical locations. Instead, the show, “Surviving Motherhood,” was taped in a local coffee shop and my first home. It was a documentary-type series that focused on challenges faced by young parents. My worry—and the reason that I agreed to be on the show—was sleep-related, as one of my children suffered from night terrors (if you’ve never witnessed them, I can promise they live up to the name). Shortly…

During his presidential campaign, Donald Trump vowed to make major changes to U.S. economic policy. That effort began with significant shifts in tariff strategy, but tax reform remained the cornerstone of his agenda. This week, the House of Representatives approved the initial version of new tax and spending legislation, dubbed the “Big Beautiful Bill.” The proposal includes tax changes that reflect many of Trump’s original campaign promises. Although the bill is still in its early stages and subject to change, the current version outlines substantial tax cuts that aim to benefit Americans across all income levels. Below is a summary…

Traders with high-volume activity could face tax on gross trading gains—even if they lose money overall. Darren Neuschwander, CPA, and Adam Manning, CPA, contributed to this blog post. Washington State has taken an aggressive stance on taxing investment and trading income under its Business & Occupation (B&O) tax regime. The October 2024 Antio court ruling and the enactment of HB 2081 in May 2025 have reshaped the landscape, potentially pulling active traders—both individuals and entities—into the tax base. The B&O tax applies to gross receipts, not net income. RCW 82.04.080 defines gross income to include trading gains, interest, dividends, and…

You would be excused if you didn’t notice, as it was not widely reported—but the IRS just open-sourced Direct File—more specifically, it released the codebase underlying the free filing program on GitHub. It isn’t every day that the IRS drops something that reads like a blend of legal code, logic theory, and open government idealism. But that is exactly what it did, laying Direct File bare—and releasing it into the public domain—for the world to scrutinize, fork, or admire in stunned silence. At the heart of this code disclosure is something called the Fact Graph, a dry name for a…