We can help you cleanly exit from the US system -- we know the tax rules and have been through the process many times.

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Real Estate

Buying the property correctly is the secret to tax success. We know how to set things up correctly from the start.

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Foreign Trusts

Trusts can act as a firewall against the US tax system, but are hard to do right. We create, terminate, and fix trusts.

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For companies that operate across the US border, we can help with the complexity of US tax planning.

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October 18, 2016

Why a Holding Company for Active Businesses is Probably Not a PFIC

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”.

Superannuation Newsletter

We are launching a new bi-weekly newsletter dedicated to superannuations, starting Wednesday, October 26, 2016. We will be making posts regularly on its dedicated website (coming soon) weekly on Monday, Wednesdays, and Fridays.

Please sign up for the newsletter at to learn how to solve superannuation tax problems, and to receive the announcement that the new website has been launched.... continue reading

October 14, 2016

Everyone Has a Plan ‘Til They Get Punched in the Mouth

Welcome to The Friday Edition, the biweekly newsletter on international tax things, because, well, that’s what I do in my day job.

This episode is for people who are aware that they have a tax problem. You might be running a business and know that there are a lot of unfiled forms (Form 5471 is a favorite) you need to take care of. Or you might not have filed tax returns for years. Or you earned income but did not report it for taxes.

In one way or another you have reached the jumping-off point. You have realized there is a problem, and you need to solve it.... continue reading

October 11, 2016

Easy Math for Determining Long-Term Resident Status

Hello and welcome to Expatriation Only, the biweekly newsletter that focuses on people renouncing U.S. citizenship or giving up green cards.

This week’s edition was triggered by a query from a reader, who was unclear about how green card holders figured out whether the exit tax rules applied to them (or not).

The exit tax rules apply to expatriates. Citizens become expatriates by relinquishing U.S. citizenship. Immigrants become expatriates by (1) being immigrants for a long time, then (2) giving up their immigrant visa status.

Immigrants who hold their permanent resident visas (green cards) for long enough to be hit by the exit tax are called long-term residents.... continue reading

October 6, 2016

Hear Atossa Abrahamian Speak About Buying and Selling Citizenship

There is a booming trade in selling citizenship and permanent resident status as a path to citizenship. People think that only small countries do this. While small countries do sell passports (St. Kitts is a prominent example), large countries do this as well. Even the United States, under the guise of the EB-5 “buy a green card” program, provides a path to American citizenship for the well-to-do.

We are seeing the rise of a new type of person–the multinational individual. Tax professionals have long known how to deal with multinational business operations, but now we are confronted with the same high level of multi-country tax complexity, applied to people.... continue reading

October 6, 2016

Reading a Profit and Loss Statement for the PFIC Income Test

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

Shortcuts for determining PFIC status

This week’s newsletter topic is a question from email:

I have a client who owns a 10% stake in a European manufacturing company. There are no other US shareholders. I received a profit and loss statement that shows gross receipts from sales, operating expenses that do not distinguish between direct and indirect expenses, and other income.

... continue reading
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Featured Event

CalCPA: Foreign Trust Series

When: November 9th, 2016 8:30AM – 12:30PM

Where: Webcast hosted by CALCPA

Foreign Trusts: The Basics
Haoshen Zhong
Time: 8:30 AM – 9:30AM
Transactions with foreign trusts have significant information reporting requirements, and they often come with tax consequences.

International Tax Lunch

October: International Tax Lunch

The Portfolio Interest Exception: All Secrets Revealed

Foreign lenders can make mortgage loans on U.S. real estate and collect the interest tax-free.  This month, Phil talks about the portfolio interest exception.  

See All Events