Foreign Corporate Tax – How Will it Impact the US Taxpayer of a CFC or PFIC?

While the focus of today's post is how the United Arab Emirates (UAE) forthcoming Corporate Tax (CT) may impact US persons who are shareholders in a so-called Controlled Foreign Corporation (CFC) or Passive Foreign Investment Company (PFIC), the analysis applies equally to other jurisdictions which impose tax on the corporate entity.  We examine today the … Continue reading Foreign Corporate Tax – How Will it Impact the US Taxpayer of a CFC or PFIC?

UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II

As discussed in my prior blog post, full details here, on January 31, the United Arab Emirates (UAE) Ministry of Finance announced the introduction of a federal corporate tax (CT) on business, to be implemented in June 2023. The UAE is joining the other Gulf Cooperation Council countries (with exception for Bahrain) that collect tax … Continue reading UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part II

UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part I

My most recent article, co-authored with Clarence Ellis and published by Bloomberg, is copied in full below. The article examines in unique detail the latest news in the tax world of the United Arab Emirates (UAE), which announced it will start to impose tax on business enterprises in the Emirates. Before you read the full … Continue reading UAE Federal Corporate Tax: How Will it Impact the US Taxpayer? Part I

GILTI – Act Now! Stop Toxic GILTI Changes on the Horizon

On November 8, 2020, I participated in a podcast with attorney John Richardson. We discussed some of the reasons why the incoming administration was likely to increase the pressure on Americans abroad. The podcast is here. On March 25, 2021 the Senate Finance Committee held a hearing on International Taxation. The hearing discussed changes to … Continue reading GILTI – Act Now! Stop Toxic GILTI Changes on the Horizon

Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

Looking at Mr. Biden’s tax proposals and now faced with his win of the presidency, coupled with Democrat control of the House, Americans abroad are in for a rough time.  This is especially true for anyone considering giving up US citizenship or long term permanent residency (LTR).  Those thinking about expatriation must take immediate action … Continue reading Mr. Biden’s Tax Plans – Serious Pain in Store for those Expatriating, Pain for Americans Abroad…. And Others!

IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)

Most of my readers have heard about Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”).  My earlier blog post provided significant detail about this tax law provision which was intended to move the US international tax regime into a “territorial system”.  In making … Continue reading IRS Eye on You! Newest Campaign: Repatriation Tax (IRC Section 965)