Former UN Income Tax Unit — Insider Expertise

Specialized U.S. Tax Services for UN & International Organization EmployeesStaff Assessment, Tax Equalization, Section 893 & Cross-Border Planning

UN compensation is unlike any other. Staff assessment, tax equalization, dependency allowances, education grants, and unique SECA rules create a tax situation that most general tax preparers simply do not understand. We do — because we have been on both sides of the table.

IRS Enrolled Agent
Former UN Income Tax Unit
UN Agencies Worldwide
FBAR & FATCA Compliance

If you are an American citizen working for the United Nations, IMF, World Bank, or any other international organization, your tax situation is genuinely unlike that of any other expat. Your salary may be exempt from local income tax. You may receive tax equalization reimbursements. Your pension contributions, dependency allowances, and education grants each have distinct U.S. tax treatments. And yet — you still must file a U.S. federal tax return every single year.

The vast majority of tax preparers have never laid eyes on a UN compensation statement. They do not know what staff assessment is, how to classify tax equalization payments, or why defaulting to the Foreign Earned Income Exclusion can actually cost a UN employee money. This gap in understanding leads to costly errors, missed opportunities, and in some cases, IRS scrutiny that could have been avoided entirely.

At Lizo Tax Consulting, we specialize in this exact niche. Rhymus Lizo is not only an IRS Enrolled Agent — he has six years of insider UN experience including a staff appointment in the UN Income Tax Unit in Geneva, where he handled the tax affairs of UN employees from dozens of countries. That insider perspective means we understand your situation from both sides of the table.

Key Insight

UN salaries are generally exempt from U.S. income tax under the UN Headquarters Agreement — but you must still file a U.S. tax return and report the income as exempt. Failing to file, or filing incorrectly, can trigger IRS penalties and jeopardize your compliance standing. The exemption and the filing obligation are two separate requirements.

UN employee US taxesAmericans working at UN taxUN tax equalization US filing
The Core Question

Do UN Employees Have to Pay U.S. Taxes?

The short answer: your UN salary is generally exempt from U.S. income tax, but you still must file a return. Other income, reimbursements, and allowances may be fully taxable. Here is how it breaks down.

Generally Exempt

Under UN Headquarters Agreement

  • Base salary from UN agencies, IMF, World Bank, and most international organizations
  • UN pension contributions while actively employed (not distributions)
  • Certain dependency allowances and education grants (partial or full exemption)
  • Post adjustment and hardship allowances in many cases
  • Staff assessment (the UN equivalent of income tax) is not deductible as a foreign tax

Typically Taxable

Must Be Reported on Form 1040

  • Tax equalization reimbursements — partially taxable depending on the specific arrangement
  • Spousal income and self-employment income earned outside the UN
  • Investment income, rental income, and capital gains from personal assets
  • UN pension distributions after retirement (treated as ordinary income)
  • Income from teaching, consulting, or other side activities while on UN assignment

The Complexity Trap

Because your UN salary is exempt, many employees assume they owe nothing to the IRS and skip filing altogether. That is a mistake. Even with exempt salary, you must file Form 1040 to report the exemption. Beyond that, your tax equalization reimbursements, spousal income, investments, and side income may all generate real U.S. tax liability.

And here is the deeper issue: tax equalization reimbursements are not treated uniformly. Some are taxable, some are not, and the distinction depends on the specific language of your organization's tax equalization policy. A general tax preparer who has never reviewed a UN tax equalization memo will almost certainly get this wrong.

UN-Specific Topics

UN Compensation & Unique Tax Issues

These three areas are where most UN employees get into trouble — and where specialized expertise makes the biggest difference. Select a topic to dive deeper.

How Tax Equalization Works for UN Employees

Tax equalization is a reimbursement system where the UN ensures employees do not pay more or less tax than they would in their home country. If your hypothetical U.S. tax liability exceeds what you actually paid locally, the UN reimburses the difference. If you paid more locally than your hypothetical U.S. liability, you may owe the UN a refund.

The U.S. tax treatment of these reimbursements is nuanced. Reimbursements that relate to your exempt UN salary are generally not taxable. However, reimbursements that relate to taxable income (such as spousal earnings or investment income) may be taxable. The distinction depends on how your organization's tax equalization policy is structured and what the reimbursement specifically covers.

Pro tip: We always request the full tax equalization memo from your organization's payroll office. Without that document, it is impossible to classify reimbursements correctly. This is one of the first things we do for every new UN client.

Staff Assessment

The UN deducts staff assessment from your salary as its internal tax equivalent. This is not a foreign tax and cannot be claimed as a Foreign Tax Credit on your U.S. return.

Dependency Allowances

Additional payments for dependent children and spouses. The U.S. tax treatment varies — some are fully exempt, others partially taxable. Correct classification matters.

Education Grants

Reimbursements for children's education costs. Under certain conditions, these may be tax-free in the U.S. We verify the specific rules that apply to your posting.

Critical Compliance

Section 893, Tax Equalization & Staff Assessment

These three areas are where most UN employees get into trouble — and where insider UN experience makes the biggest difference.

Tax Equalization

Tax equalization is a reimbursement system where the UN ensures employees do not pay more or less tax than they would in their home country. The U.S. tax treatment of these reimbursements is nuanced — some are taxable, some are not, depending on what specific income the reimbursement relates to.

  • We always request the full tax equalization memo from your payroll office
  • Reimbursements related to exempt UN salary are generally not taxable
  • Reimbursements related to taxable income may be fully taxable
  • Incorrect classification is one of the most common UN tax errors

Staff Assessment

Staff assessment is the UN's internal equivalent of income tax, deducted from your salary. It is not a foreign tax paid to a sovereign government, and therefore it does not qualify for the U.S. Foreign Tax Credit.

  • Cannot be claimed as a Foreign Tax Credit on your U.S. return
  • This is a common misconception that leads to incorrect filings
  • Staff assessment is deducted before your net salary is calculated
  • Understanding its role is essential for accurate U.S. reporting

Section 893 Awareness

Section 893 of the U.S. tax code provides exemptions for employees of international organizations. However, the exemption applies only to specific types of income and requires proper documentation and reporting.

  • Applies to salaries from qualifying international organizations
  • Does not eliminate the U.S. filing obligation — only the tax on exempt income
  • Other income (investments, spousal earnings) remains fully taxable
  • Proper Form 1040 reporting is required to claim the exemption

Why FEIE Is Usually the Wrong Choice for UN Employees

Because your UN salary is already exempt from U.S. tax under the UN Headquarters Agreement, using the Foreign Earned Income Exclusion provides no additional benefit on that income. In fact, it can reduce your ability to claim other credits and may produce a worse overall outcome.

We analyze both FEIE and Foreign Tax Credit for every UN client, but in most cases, the FTC approach — or simply reporting the exempt income correctly — produces the best result. This is the kind of insight that comes from having processed UN tax returns from the inside.

Global Mobility

International Assignments & Multi-Country Postings

UN and international organization employees often move between countries every few years. Each move changes your tax position. Here is how we plan for it.

Short-Term Assignments (Under 1 Year)

  • May not establish bona fide residence in the host country
  • FEIE physical presence test may still be met with 330 days abroad
  • Tax equalization reimbursements may still apply for short-term hardship postings
  • State tax obligations often continue uninterrupted
  • Housing allowances and per diems have specific U.S. tax treatments

Medium-Term Assignments (1–3 Years)

  • Often sufficient to establish bona fide residence for FEIE purposes
  • May become a tax resident of the host country, triggering dual filing
  • Tax treaty tie-breaker rules may determine which country is the "residence" for treaty purposes
  • UN-specific: the UN-Sweden Agreement may exempt salary from host country tax
  • Family relocation expenses and education costs may have tax implications

Long-Term & Career Assignments (3+ Years)

  • Almost always establishes bona fide residence and host country tax residency
  • Retirement planning becomes critical — pension contributions, distributions, and rollovers
  • Property ownership in the host country adds complexity (rental income, capital gains, inheritance)
  • Children born abroad may have citizenship and tax implications
  • eventual repatriation or retirement relocation requires multi-year tax planning

The Multi-Country Bank Account Problem

A typical UN employee may have bank accounts in four or more countries over a career: Geneva, New York, a field posting, and a spouse's home country. Each account must be tracked for FBAR purposes. The aggregate balance test means even small accounts in multiple countries can trigger the $10,000 threshold.

We help UN employees maintain a clean account inventory throughout their career, ensuring no account is missed when FBAR season arrives. For those already behind, we handle multi-year catch-up filings through the Streamlined Procedures.

U.S. Side

U.S. Filing Requirements for UN Employees

These are the forms and filings every American UN employee should understand. Missing any of them can lead to penalties, interest, and in the case of FBAR, severe financial consequences.

Critical
Form 1040

U.S. Individual Income Tax Return

Even though your UN salary is exempt, you must still file Form 1040 every year. You report your UN salary on the return and claim the exemption under the UN Headquarters Agreement. Other income (investments, spousal earnings, etc.) is reported normally.

Form 1116

Foreign Tax Credit

If you have taxable income in your posting country (such as spousal income or rental income), the Foreign Tax Credit may offset U.S. taxes on that income. Staff assessment is NOT a foreign tax and does not qualify for FTC.

Form 2555

Foreign Earned Income Exclusion

For UN employees, FEIE is rarely the right choice. Because your UN salary is already exempt under the UN Agreement, using FEIE on other income may reduce your ability to claim credits and can produce a worse outcome. We analyze both FTC and FEIE carefully.

Critical
FBAR (FinCEN 114)

Report of Foreign Bank Accounts

Required if the aggregate value of all your foreign financial accounts exceeded $10,000 at any point during the year. This includes accounts in your posting country, Swiss accounts, and any other offshore holdings. Filed separately with FinCEN.

Critical
Form 8938

Statement of Specified Foreign Financial Assets (FATCA)

Required if your foreign financial assets exceed certain thresholds ($200,000 at year-end for single filers abroad). Unlike FBAR, this is filed with the IRS as an attachment to Form 1040. Both FBAR and FATCA may be required.

Form 8832 / 8833

Entity Classification & Treaty Disclosure

If you have a foreign business entity, a trust, or are claiming treaty benefits beyond the UN Agreement, additional disclosures may be required. Entity classification elections and treaty-based return position disclosures protect your filing.

A Word on Penalties

FBAR non-compliance penalties can be devastating — up to $16,536 per non-willful violation (adjusted for inflation), and the greater of $165,353 or 50% of the account balance for willful violations. FATCA Form 8938 carries a $10,000 initial penalty, with additional penalties up to $50,000 for continued failure to file.

The Streamlined Foreign Offshore Procedures program allows Americans who were non-willful in their failure to file to come back into compliance without penalties. We have guided many UN employees through this process discreetly.

Learn more about FBAR & Compliance
Pitfalls to Avoid

Common Mistakes UN Employees Make

These are not hypothetical problems — they are the actual issues we fix when new clients come to us after filing with a general tax preparer who did not understand UN compensation.

Critical

Assuming No Filing Is Needed Because Salary Is Exempt

This is the single most dangerous misconception among UN employees. The UN Headquarters Agreement exempts your salary from U.S. income tax — but it does not exempt you from the filing obligation. You must still file Form 1040 every year and report your exempt income.

Critical

Misreporting Tax Equalization Reimbursements

Many UN employees incorrectly classify tax equalization reimbursements as fully exempt or fully taxable. The reality is more nuanced — some reimbursements relate to exempt salary and are not taxable, while others relate to taxable income and must be reported. Getting this wrong is a red flag for the IRS.

High Risk

Ignoring SECA Liability on Side Income

If you have self-employment income outside the UN — consulting, teaching, freelance work — you may owe SECA tax at 15.3%. Many UN employees assume the FICA exemption covers all their income. It does not. Only UN salary is exempt from FICA; other earned income is subject to self-employment tax.

Critical

Skipping FBAR and FATCA Filings

Foreign bank accounts held in your posting country, Switzerland, or anywhere else must be reported if the aggregate balance exceeded $10,000 at any point. UN employees often have accounts in multiple countries and assume the UN exemption covers reporting. It does not.

High Risk

Misclassifying Education Grants and Dependency Allowances

These payments have specific U.S. tax rules. Some are fully exempt under the UN Agreement, others are partially taxable, and a few may be fully taxable depending on how they are structured. A general tax preparer will almost certainly not know the difference.

High Risk

Defaulting to FEIE Without Analysis

Because UN salary is already exempt, using the Foreign Earned Income Exclusion on other income can backfire. FEIE may reduce your ability to claim the Foreign Tax Credit on spousal or investment income. For most UN employees, a detailed FTC analysis produces a better result than blind FEIE.

Medium Risk

Failing to Plan for Post-UN Tax Residency

Where you go after your UN assignment ends has massive tax implications. Retiring to Spain with a UN pension is very different from retiring to Portugal or returning to the U.S. These decisions should be made years in advance, not months before your contract ends.

Medium Risk

Missing the Streamlined Filing Window

If you have years of unfiled returns, the Streamlined Foreign Offshore Procedures program is your best path back to compliance. But it requires a non-willfulness certification. The longer you wait, the harder it becomes to argue non-willfulness convincingly.

Expert Perspective

Real-World Insights From the Desk

These are not generic tips pulled from a manual. They are observations from nearly 20 years of helping UN employees navigate U.S. tax law — including six years of insider UN experience with a staff appointment in the UN Income Tax Unit itself.

01

The "My Salary Is Exempt, So I Do Not Need to File" Trap

This is the mistake we see most often, and it is almost always discovered during a routine IRS inquiry or when the employee applies for a mortgage back in the U.S. The UN Headquarters Agreement exempts your salary from tax — not from reporting. Failing to file Form 1040 is a separate violation, and the IRS can still assess failure-to-file penalties. We have had clients who went a decade without filing because someone — a colleague, a friend, even another accountant — told them it was not necessary. It was.

02

Tax Equalization Memos Are Not Optional

Every UN organization produces a detailed tax equalization memo that explains exactly how reimbursements are calculated and classified. These memos are not optional reading material — they are the primary document we use to determine the U.S. tax treatment of your reimbursements. Yet many clients come to us having never seen their memo. Their previous preparer did not ask for it. Without it, we are guessing. With it, we are precise.

03

The FICA Exemption Does Not Cover Side Income

We have seen UN employees who taught a course on the side, consulted for a local firm, or ran a small online business assume their FICA exemption from the UN covered that income too. It does not. Self-employment tax on $30,000 of side income is over $4,500. That is a painful surprise if you did not plan for it. We always ask about side income during our intake — because the IRS will ask about it eventually.

04

Retirement Location Determines Pension Tax

A UN pension paid to a U.S. resident is taxed as ordinary income at federal rates. The same pension paid to a resident of Portugal under the NHR regime may receive dramatically better treatment. The same pension paid to Spain may be taxed differently depending on the U.S.-Spain treaty. We have clients who saved tens of thousands of dollars per year simply by choosing their retirement jurisdiction strategically. This is not tax evasion — it is tax planning, and it is entirely legal.

05

G-4 Visa Holders Have Unique State Tax Rules

G-4 visa holders who maintain a U.S. domicile may still have state tax obligations even while posted abroad. Some states — notably California and Virginia — are aggressive about taxing former residents. Others, like Texas or Florida, have no income tax and pose no issue. Whether you can sever state ties depends on what you keep: property, voter registration, drivers license, and where your family lives. We map this out for every client during onboarding.

06

The Best Time to Plan Is Before Your Contract Ends

We get calls from UN employees three months before retirement asking what they should do. By then, many of the best options are off the table. The optimal time to plan your post-UN tax strategy is two to three years before your contract ends. That gives us time to model different scenarios, coordinate with your UN pension office, and potentially restructure investments or residency plans before you are locked in.

Important Dates

Tax Deadlines UN Employees Need to Know

Missing a deadline on either side can be expensive. Here is the timeline you need to track.

U.S. Deadlines

April 15

U.S. tax payment due (if taxes are owed)

Even with the automatic June 15 filing extension, taxes owed are still due April 15. Interest and penalties accrue from that date.

June 15

Automatic expat filing extension

Americans living abroad get an automatic 2-month extension to file. This is not an extension to pay — only to file.

June 30

FBAR filing deadline

FBAR (FinCEN Form 114) must be filed electronically by June 30. No extensions are available for FBAR.

October 15

Extended filing deadline

If you request an additional extension, your filing deadline moves to October 15.

Critical: Even with the automatic June 15 filing extension, any taxes owed to the IRS are still due April 15. Interest and penalties accrue from that date.

UN & Posting Country

Varies

Local tax filing in posting country

Each country has its own tax calendar. If you have non-UN income in your posting country, local filing obligations apply independently of your U.S. deadlines.

Ongoing

UN payroll tax equalization reconciliation

Most UN organizations reconcile tax equalization on an annual or bi-annual cycle. Delays in submitting your U.S. tax return to the UN payroll office can delay reimbursements.

End of Contract

UN lump-sum / pension election deadline

When leaving the UN, you typically have a limited window to elect how to receive your separation payment and how to handle accumulated pension rights.

Note: We coordinate your U.S. filing timeline with your UN payroll reconciliation cycle to ensure tax equalization reimbursements are processed without delay.

Our Clients

Who We Help

We work with Americans across the UN system in every career stage. Here is who we serve most often.

UN Agency Staff

Headquarters and field office employees of UNDP, UNICEF, UNHCR, WHO, ILO, and other UN agencies. We handle tax equalization analysis, FBAR compliance, and multi-year filing coordination.

IMF & World Bank Employees

Staff of the International Monetary Fund and World Bank Group. These organizations have distinct compensation structures and tax policies that require specialized knowledge.

Other International Organizations

OECD, NATO, European Bank for Reconstruction and Development, and other treaty-based organizations. Each has unique tax arrangements that general preparers do not understand.

UN Spouses & Dual-Income Households

When one partner works for the UN and the other has local employment or self-employment income, the tax coordination becomes significantly more complex. We handle both sides.

Retired UN Employees

Navigating UN pension distributions, choosing a tax-efficient retirement jurisdiction, and coordinating with local tax advisors in Spain, Portugal, or other destinations.

Non-Filers Catching Up

Americans who have not filed U.S. returns in years and need to come back into compliance through the Streamlined Foreign Offshore Procedures. We handle these cases with discretion.

Why Work With Us

Why UN Employees Choose Lizo Tax Consulting

There is no shortage of tax preparers who will file your return. What sets us apart is the depth of UN-specific expertise and the personal attention we bring to every client relationship.

IRS Enrolled Agent

Rhymus Lizo is a federally authorized tax practitioner with unlimited practice rights before the IRS. We represent clients in audits, appeals, and complex matters — not just prepare returns.

Insider UN Experience

Six years of insider UN experience — including a staff appointment in the UN Income Tax Unit in Geneva — gives us a perspective that virtually no other tax professional can offer. We understand UN compensation from the inside out.

Multi-Organization Experience

We have served clients from UNDP, UNICEF, UNHCR, WHO, IMF, World Bank, OECD, NATO, and more. Each organization has its own nuances, and we know them.

Cross-Border Coordination

We do not just file your U.S. return in isolation. We review your local tax position, coordinate with advisors in your posting country, and ensure your filings tell a consistent story.

Year-Round Availability

Tax questions do not wait for April. We are available throughout the year for planning, questions, and mid-year strategy adjustments. Our clients are not just a once-a-year transaction.

Discretion & Security

We use bank-level security for document exchange and maintain strict confidentiality. For UN employees with sensitive positions, we offer additional discretion protocols.

15+Years of Tax Experience
50+Countries Served
6Years of UN Experience
UN & International Organizations

UN Employee Tax Support

Specialized U.S. tax filing and year-round guidance for UN employees, international organization staff, and their families.

UN employees have tax situations that ordinary tax preparers may not understand. Between UN income treatment, reimbursements, possible §893 issues, foreign bank accounts, dependents abroad, state residency questions, and FBAR requirements, you need guidance from someone familiar with UN tax issues.

Lizo Tax provides structured monthly support for UN employees. Your annual U.S. federal tax return is included, and you have access to guidance throughout the year instead of only during tax season.

Existing Lizo Tax clients pay no setup fee. Setup fees apply only to new clients.

UN Basic

€19.95/month
New Client Setup:€150
Existing Client Setup:Waived

Best for

Simple UN employees or W-2 taxpayers with straightforward U.S. tax filings.

Includes

  • Annual U.S. federal tax return
  • UN income treatment review
  • Basic §893 / UN employee tax treatment review
  • Dependents and simple credits
  • Simple interest, dividends, and basic investment income
  • Basic IRS notice guidance related to the filed return
  • One annual 30-minute consultation
  • Basic email support during tax season

Ideal for

  • UN income only
  • Simple W-2 income
  • Dependents
  • Child tax credit or dependent credits
  • Simple investments
  • No FBAR requirement
  • No rental property
  • No self-employment
  • No complex foreign investments
Choose UN Basic
Most Popular

UN Global

€39/month
New Client Setup:€250
Existing Client Setup:Waived

Best for

UN employees living abroad who need U.S. tax filing, FBAR support, and basic cross-border guidance.

Includes

  • Everything in UN Basic, plus:
  • FBAR filing
  • Foreign bank account reporting guidance
  • Foreign address and expat filing review
  • UN reimbursement review
  • Basic state residency / domicile review
  • Tailored UN tax guidance map
  • One 30-minute tailored consultation
  • One 30-minute consult per quarter
  • One email correspondence per week
  • IRS extension filing if needed

Ideal for

  • UN employees living outside the U.S.
  • Foreign bank accounts
  • Dependents abroad
  • Foreign spouse or mixed-residency questions
  • Basic foreign tax coordination
  • Simple investments
  • State residency questions
Choose UN Global

UN Advisory

€124.95/month
New Client Setup:€500
Existing Client Setup:Waived

Best for

Senior UN employees, reassignment years, multi-country situations, and complex family or financial cases.

Includes

  • Everything in UN Global, plus:
  • Monthly 30-minute advisory consultation
  • Annual UN tax planning review
  • Reassignment and relocation tax planning
  • UN reimbursement and tax reimbursement analysis
  • Multi-country coordination guidance
  • Treaty-sensitive issue review
  • Basic tax projection planning
  • IRS notice support related to the filed return
  • Priority email support
  • Year-round strategy support

Ideal for

  • Senior UN employees
  • Multi-country tax residency issues
  • Spouse with W-2 / business / rental / investment income
  • Relocation or reassignment years
  • Large UN reimbursements
  • Foreign pensions or foreign employer benefits
  • Prior-year cleanup
  • IRS balance due or notice issues
  • Complex planning needs
Choose UN Advisory
Year-Round, Not Just Tax Season

UN Tax Questions Arise All Year

Reassignment notifications, reimbursement confusion, foreign account openings, and state residency changes do not wait for April. With structured monthly support, you get answers when you need them — not months after the issue has grown.

Quarterly or monthly consultations included
Email support throughout the year
Annual return included in your plan

Start with a free 30-minute fit call. We will review your UN income structure, assignment history, and recommend the right support tier.

Schedule Strategy Session

Why UN Tax Is Unique

What Makes UN Tax Different?

UN employees often face tax issues that regular tax preparers may overlook. Your income may be treated differently depending on your citizenship, role, country of assignment, visa status, reimbursement structure, spouse income, and whether you have foreign accounts. You may also have U.S. filing obligations even while living abroad, including FBAR reporting if foreign financial accounts exceed the reporting threshold.

Lizo Tax helps UN employees understand what needs to be filed, what needs to be reviewed, and what planning opportunities or risks may apply before problems arise.

Comprehensive Coverage

Common UN Tax Issues We Help With

U.S. federal tax filing for UN employees
UN income and reimbursement review
§893 tax treatment review
FBAR filing and foreign account reporting
Dependents and child tax credits
Foreign spouse and mixed-residency questions
State residency and domicile concerns
Foreign assignment and reassignment planning
IRS notices related to filed returns
Coordination with foreign tax residency issues

Questions & Answers

UN Employee Tax FAQ

Many U.S. citizens and green card holders working for the UN still have U.S. filing obligations. The correct treatment depends on citizenship, role, income type, assignment location, and whether other income exists.

FBAR is included in the UN Global and UN Advisory plans. UN Basic is for simple cases without FBAR requirements.

No. Existing Lizo Tax clients do not pay a setup fee. Setup fees apply only to new clients.

No. These plans are for U.S. tax filing and UN-related U.S. tax guidance. Foreign country tax preparation is quoted separately.

Ready to Get Your UN Tax Strategy Right?

Stop guessing and stop overpaying. Get a clear picture of your U.S. tax obligations as a UN employee — from someone who has been on both sides of the table.

Start with a free 30-minute fit call. No obligation. Straight answers about your specific UN tax situation.

FAQ

Frequently Asked Questions

Answers to the questions UN employees ask us most often.

Yes. UN salaries are generally exempt from U.S. income tax under the UN Headquarters Agreement and related international agreements. However, you must still file a U.S. tax return every year and report the exempt income. The exemption applies to the tax itself, not the filing obligation.

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