Carolyn, a self-employed education consultant, is a Canadian citizen working in the United States on a temporary worker visa. Upon expiration of her visa Carolyn is required to obtain a Green Card to continue working with many of her clients in the United States. Carolyn obtains a Green Card, but pays attorney and filing fees amounting to $9,000 in the process. How much of this amount, if any, may Carolyn deduct on her return?

Note: you are expected to complete this project using current, post-CARES Act law. In other words, apply “new” law to the fact patterns below. To the extent your conclusion is contingent on an unknown fact, you should discuss possible outcomes for different assumptions.

In general, the memos should document the analysis you performed and conclusions of your research. More specifically, the memos should reflect the following about each client’s inquiry: 

• Relevant facts
  Issues (questions) identified from the facts
  Applicable primary authority (importantly, IRS Publications may not be your only source for any particular client inquiry)
  Conclusions and recommendations reached as a consequence of your research 
• Analysis performed (i.e., how the primary authority cited above addresses the issues)