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

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 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

Real Life Examples: A US Tax Mess, International Community Property

Attention all mixed nationality couples, with one spouse having US citizenship or US resident status while the other is a nonresident alien (NRA)!  Your tax advisor should be looking at all possible issues surrounding your fact pattern.  If you live in a foreign jurisdiction or US state (there are 9 of them) with a community … Continue reading Real Life Examples: A US Tax Mess, International Community Property