PFICs – The Fairytale Definition That Lives Happily Ever After…

I was hoping that tax reform would have done away with, or at least modified, the troublesome provisions surrounding the PFIC or so-called “Passive Foreign Investment Company”.  This was not to be and it prompted me to review the PFIC rules and count the ways they cause trouble! What is a PFIC? A PFIC is … Continue reading PFICs – The Fairytale Definition That Lives Happily Ever After…

Before You Think of Becoming an “American Abroad”, Read This….

I was recently asked about the tax problems faced by Americans who move overseas.  Unfortunately, there are many US tax difficulties faced by Americans abroad. In order to make some sense of this vast topic, let's put the major problems into several basic categories.  Once aware of the problems lurking out there, you can get … Continue reading Before You Think of Becoming an “American Abroad”, Read This….

US Owners of Foreign Corporations – Beware the Downsides

My earlier blog post introduced readers to the concepts of so-called CFCs and PFICs and some of the downsides of owning a "foreign" corporation. It analogized to quicksand simply because it is very easy to be swallowed up in harsh tax results and onerous reporting obligations if planning is not undertaken beforehand. I will remind … Continue reading US Owners of Foreign Corporations – Beware the Downsides

FORM 8938: Infinite Statute of Limitations & Everything Else You Need to Know

My prior blog post gave details about how the Form 8938, an important “Foreign Account Tax Compliance Act” (FATCA) enforcement weapon, is currently failing.  IRS enforcement efforts are soon on the upswing.  This is because the Treasury Inspector General for Tax Administration issued a report over the summer pointing out the IRS' failures with regard … Continue reading FORM 8938: Infinite Statute of Limitations & Everything Else You Need to Know

Quicksand! US Owners of Foreign Corporations

It is usually very quick and easy to set up a foreign corporation - say, one in Belize or in the Cayman Islands.  What is not so easy is working one's way through the quagmire of required Internal Revenue Service (IRS) reporting and US  tax obligations simply because you are a US person owning shares … Continue reading Quicksand! US Owners of Foreign Corporations

Transfer of Property or Cash to a Foreign Corporation? FILING OF FORM 926

US persons (e.g., US citizens, US green card holders) must make an information report to the IRS when making certain transfers to foreign (non-US) corporations. Specifically, when a US person transfers (or is treated under the tax rules as having transferred) property to a foreign corporation in certain “non-recognition” transactions (e.g., a contribution of capital … Continue reading Transfer of Property or Cash to a Foreign Corporation? FILING OF FORM 926

Dividends from Foreign Corporations Part III – “Controlled Foreign Corporations”

Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends".  It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Part I, Part II and below, Part III.  Unsurprisingly, many US owners of corporations that are … Continue reading Dividends from Foreign Corporations Part III – “Controlled Foreign Corporations”

Dividends from Foreign Corporations Part II – “Controlled Foreign Corporations”

Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends".  It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Access links here Part I, Part II (which appears below) and Part III.  Unsurprisingly, many US owners of corporations … Continue reading Dividends from Foreign Corporations Part II – “Controlled Foreign Corporations”

Dividends From Foreign Corporations – Understand Your Investment! PART I

Learn about the interplay between foreign corporations and eligibility for lower tax rates available only for "qualified dividends".  It's a complicated topic and all of the posts in the series should be read in order to understand the ramifications. Below is Part I, and you can access the remaining posts at these links Part II and Part III.  … Continue reading Dividends From Foreign Corporations – Understand Your Investment! PART I

Section 965 “Transition Tax”: It’s Time to Pay the Piper

Copied below is my post as it appeared (March 21 2018) on my former blog "Let's Talk About US Tax" when hosted by Anglo Info. By now I suspect many of my readers have heard about (and are shedding tears over) new Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by … Continue reading Section 965 “Transition Tax”: It’s Time to Pay the Piper