My earlier blog post explained the unpleasant tax effects that occur when a US person receives a "gift" from a foreign corporation or a foreign partnership. Yes, bad things happen. The general tax treatment for gifts will not apply. Usually, a gift is not treated as taxable income to the recipient. However, when the gift … Continue reading “Purported Gifts” from a Foreign Corporation or Partnership- Exceptions & Application of PFIC Rules
Several of my recent blog posts set the stage showcasing the serious US tax issues that can arise for a married couple when only one is a US person and they are impacted by application of a foreign country’s community property laws. You can read these blog posts here, here and here. For example, if funding … Continue reading D is for “Domicile”, Don’t Disregard!
I will be posting here a series of eight related videos which discuss the premise that the United States is imposing a separate and more punitive tax system on U.S. dual citizens who live in (and are tax residents of) other countries. The videos were motivated by recent posts by Toronto lawyer John Richardson and … Continue reading Americans Abroad: Separate But (Not) Equal
Regular readers of my tax blog will not be surprised by the title of this post and the content it hints at delivering. They likely realize by now that the American person abroad is not looked upon favorably by the US tax laws. The tax laws look at anything “foreign” with a jaundiced eye when … Continue reading US Tax Law to American Abroad – “How Do I Hate Thee, Let Me Count the Ways”
What Every Overseas American Investor Must Know …. Many American investors are confused by sales pitches of expat investment advisors who are most often completely unfamiliar with US tax laws. While it is true that no tax may be payable in the fund's jurisdiction (Isle of Man, Guernsey or the UAE, for instance), significant US … Continue reading US Tax Disaster – Investing in Offshore Funds, Life Policies, Portfolio Bonds
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….
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
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
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
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”