Cross-border technical knowledge: Understanding of controlled foreign corporations, foreign branches, Subpart F, net CFC tested income, passive foreign investment companies, PFIC excess distributions, foreign tax credit optimization, foreign trusts, treaty positions, and check-the-box elections. International tax knowledge: Comprehensive knowledge of Forms 3520, 3520-A, 5471, 5472, 8621, 8832, 8833, 8858, 8865, 1042, 1042-S, and 2555, along with related domestic filings such as Forms 1040, 1040-NR, 1041, 1065, 1120, and 1120-S.