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May 24, 2016

The Dual Citizen Exception to Covered Expatriate Status

Hello everyone. It’s Phil Hodgen, and welcome to Expatriation Only, the email newsletter that I send out every other Tuesday.

If you want to unsubscribe from this list, just click the “unsubscribe” link at the bottom of the email.

Dual Citizen Exception

This week, let’s look at the dual citizen exception to covered expatriate status.

When you renounce your U.S. citizenship, you will be characterized as a “covered expatriate” — or not. It is better to not be a covered expatriate. Covered expatriates will probably pay some tax for the privilege of leaving the U.S. tax system behind them.

There are three reasons why you would be characterized as a “covered expatriate”.... continue reading

May 19, 2016

What happens when you set up an IP licensing subsidiary

Greetings from Haoshen Zhong.

You are receiving this email because you are subscribed to our PFICs Only newsletter, delivered to your inbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom and click “unsubscribe”. To browse our other newsletters, go to hodgen.com/newsletters.

What happens when you set up an IP licensing subsidiary

This week’s newsletter topic comes from a previous client’s question:

I own 40% of a BVI corporation, and a nonresident alien owns the other 60%. The BVI corporation owns an operating corporation in country X that runs a website which makes money from subscriptions for web services.

... continue reading
May 13, 2016

When Americans Can’t Own Real Estate Abroad

Hello from Phil and welcome again to the Friday Edition. Every other Friday you get your dose of international tax news from me. If you want this email to stop, please click the “unsubscribe” link at the bottom of the email.

When Americans Can’t Own Real Estate Abroad

Many countries will not allow foreigners to own real estate. Mexico is a prominent partial example for Americans — direct real estate ownership is forbidden for property too close to the border or the coastline. Inland, no problem. Other countries flatly limit ownership of real estate to their citizens only.

I received a WhatsApp message from an American living in one such country.... continue reading

May 10, 2016

Tax Residency Starting, Termination Dates for Green Card Holders

Hey there fellow expatriation aficionados. Phil here with the every-other-Tuesday Expatriation Only newsletter.

You can unsubscribe by clicking the “unsubscribe” link at the bottom of this email.

Simple Facts Meet Dumb Systems

This week is not a strictly an expatriation topic. The person who wrote to me is a newly-minted green card holder who intends to abandon his permanent resident status after 2.5 months in the USA.

He will not be a “long-term resident” and therefore the expatriation rules will not apply to him. What WILL apply to him, however, are the tax return filing rules. In a nutshell, someone with a fleeting presence in the United States faces a requirement to file U.S.... continue reading

May 5, 2016

PFIC deemed sale gains and Net Investment Income Tax

Hi from Debra Rudd.

​You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom and click “unsubscribe”. To see what other newsletters we offer, go to hodgen.com/newsletters.​

PFIC deemed sale gains and Net Investment Income Tax

I received the following question from reader S after writing about the Net Investment Income Tax in the context of PFIC distributions:​

Along the same lines, if you were doing a deemed sale to remove the PFIC taint, would the gain from the sale still be subject to the NIIT?

... continue reading
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CalCPA: U.S. Real Estate Series

When: July 13, 2016 8:30AM to 12:30PM PDT

Where: Webcast hosted by CalCPA

Acquisition of U.S. Real Estate by Nonresidents: Selecting the Holding Structure
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: Haoshen Zhong
Time: 8:30 AM – 9:30 AM
Nonresidents who acquire U.S.

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