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Blog

April 29, 2016

Cloud Computing Taxation for Minimultinationals

Hi, Phil here again. Welcome to the Friday Edition. Every other week you get international tax stuff. When I am on a plane, you get a Jell-O Shot. (No plane rides for me, at least for a while. Too much year-end school stuff with the kids).

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Cloud Computing and International Tax

This episode is for people who own and run software companies – specifically, cloud-based companies: Platform-as-a-Service, Software-as-a-Service, etc. Mailchimp, the company that delivers the Friday Edition to you, is a perfect example of this kind of business.... continue reading

April 26, 2016

IRA Distributions for Noncovered Expatriates

Hello from Phil again, and welcome to this edition of the Expatration Only newsletter.

If you want to stop getting this newsletter (it comes every other Tuesday at 6 am Pacific Standard/Daylight Time), click the Unsubscribe button at the bottom of this newsletter.

IRA Distributions to Noncovered Expatriates

Many people have Individual Retirement Accounts when they expatriate. This time, I will talk about how to handle IRA distributions after expatriation – for noncovered expatriates. The prompt came from reader LC, who emailed me a question. Lightly edited (to hide personally-identifiable facts), this is what LC sent me:

I currently live in [country with no income tax and no income tax treaty with the USA].

... continue reading
April 21, 2016

PFIC distributions 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 distributions and Net Investment Income Tax

​Today I’m going to talk about a question I’ve received from a few different people. This particular version of the question comes from reader X:

Does the Net Investment Income Tax apply to the entire distribution I receive from my PFIC?

... continue reading
April 15, 2016

Wherein we see using a U.S. corporation is better than a tax haven corporation

Hi from Phil. Welcome to the Friday Edition, where we talk about international tax. You can stop receiving this email by clicking the unsubscribe link at the bottom of the email.

TL;DR

International tax planning is about tax deferral. Avoid the phrase “tax savings” because you will confuse yourself. You’re not saving tax. You are postponing the payment date.

Do not automatically assume that if you achieve tax deferral you have accomplished something good. The Lord giveth, and the Lord taketh away. The IRS has countermeasures.

I give an example where using a tax haven corporation can give you a bigger tax bill than using a U.S.... continue reading

April 12, 2016

Green Card Holders Abroad, Gifts, and Gotchas

Hi and welcome again from Phil. This is the every-other-Tuesday Expatriation newsletter. You can stop getting it by clicking the unsubscribe link at the bottom of this email.

Green Card Holders Abroad, Gifts, and Gotchas

James Simango emailed me to follow up on the email I did about gifts by green card holders domiciled outside the United States. (Spoiler alert: they aren’t taxable “gifts” and this makes possible all sorts of pre-expatriation tax planning). He mentioned Section 1041 and specifically the situation of gifts to noncitizen spouses mentioned in Section 1041(d).

James is right. Just because a transfer is not subject to gift tax does not mean you are out of the woods.... continue reading

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Events

International Tax Lunch

May: International Tax lunch

PFIC Tests in Depth for Operating Companies

The passive foreign investment company (PFIC) rules are mechanical tests.  An operating company that is actually doing business can fall afoul of them in the right circumstances.  

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