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 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

Calculating the Transition Tax: Just Like Dental Work – Painful in More Ways Than One

Copied below is my blog piece originally posted on AngloInfo "Let's Talk About US Tax" posted on April 4, 2018 by Virginia La Torre Jeker J.D., Most readers have some familiarity by now with new Internal Revenue Code Section 965 and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”). Introductory detail about this new … Continue reading Calculating the Transition Tax: Just Like Dental Work – Painful in More Ways Than One

Tax Primer: US Expats & Foreigners

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Everything you need to know about US tax is right here at your fingertips!  My primer provides information for overseas Americans and green card holders on US tax obligations including Income Tax, Estate Tax and Gift Tax as well as IRS reporting requirements and State income tax. It also provides detailed information for foreign individuals … Continue reading Tax Primer: US Expats & Foreigners

Form 5472 – Everything You Need To Know (Part I)

This tax filing season brought a wave of questions about Form 5472.  Interest in this complex form was renewed because of recent Treasury Regulations requiring that it be filed by single-member US LLC’s that are foreign owned. Prior to the issuance of these regulations, a single member foreign-owned US LLC was treated as a tax … Continue reading Form 5472 – Everything You Need To Know (Part I)