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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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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
Hello from Phil again, and welcome to this edition of the Expatration Only newsletter.
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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:
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I currently live in [country with no income tax and no income tax treaty with the USA].
Hi from Debra Rudd.
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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:
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Does the Net Investment Income Tax apply to the entire distribution I receive from my PFIC?
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.
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
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.
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