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 →

Overview: The Disregarded Entity & Check-the-Box

What Is a Disregarded Entity? How is it Used in US Tax Planning? Certain business entities can be treated as “nonexistent” for federal income tax purposes. That is, from a US tax perspective, they are simply “disregarded” and the entity is ignored by the Internal Revenue Service (IRS). For other purposes, the entity is not disregarded, … Continue reading Overview: The Disregarded Entity & Check-the-Box →

Americans Abroad: Sale of “Principal Residence”, Gain Exclusion, Unforeseen Circumstances & COVID-19

Section 121 of the US Internal Revenue Code allows for the exclusion of up to $250,000 ($500,000 for a married couple filing jointly) in gains arising from the sale of a "principal residence." The exclusion applies whether the residence is located Stateside or overseas. The tax law has very specific rules. Aside from the fact that … Continue reading Americans Abroad: Sale of “Principal Residence”, Gain Exclusion, Unforeseen Circumstances & COVID-19 →

Understanding Self-Employment Tax: The American Abroad

US Social Security and Medicare taxes continue to apply to “wages” for services performed as an employee working outside of the United States if you are working for an “American employer”. Many Americans abroad are employees of a foreign employer and I will write a separate blog post about their situation. Many Americans abroad are self-employed … Continue reading Understanding Self-Employment Tax: The American Abroad →

US Tax Planning Before Immigrating to the United States

Many people do not think about the possible US tax planning techniques available to them before they become taxed as US “residents”. Once taxed as a US "resident" (e.g., a green card holder) the individual must clearly understand they are liable for US income tax on their worldwide income, in the same manner as a … Continue reading US Tax Planning Before Immigrating to the United States →

Escaping Tax Penalties – “Reasonable Cause” & Reliance on Professional Advice

Today' lesson - Choose your US tax advisor very carefully. If he or she lacks the US international/foreign tax experience you may need, reliance on the tax advice may not be considered "reasonable," leading to plenty of penalties. Let's explore! Various civil tax penalties can be assessed when a taxpayer fails to pay the correct … Continue reading Escaping Tax Penalties – “Reasonable Cause” & Reliance on Professional Advice →

All You Need to Know about the 3.8% Medicare / Net Investment Income Tax & how Pres. Biden Will Expand Who Pays It

Under current law, limited partners who materially participate in a partnership's business are not subject to self-employment tax. Members of an S corporation who materially participate in the S corporation's business are subject to self-employment tax only on "reasonable compensation" received in their capacity as an “employee”. These individuals are also exempt from the 3.8% … Continue reading All You Need to Know about the 3.8% Medicare / Net Investment Income Tax & how Pres. Biden Will Expand Who Pays It →

An Eye for Moving Abroad? Bye-Bye USA, Hello Tax Complications!

Bloomberg Tax - I invite readers to enjoy my recently published article, copied in full below. Reproduced with permission. Published April 20, 2021. The Bureau of National Affairs, Inc. (800-372-1033) http://www.bloombergindustry.com. Daily Tax Report International, published online here and in PDF format here. It has certainly been a year to remember. So many changes have … Continue reading An Eye for Moving Abroad? Bye-Bye USA, Hello Tax Complications! →