We can help you cleanly exit from the US system -- we know the tax rules and have been through the process many times.Learn More
Buying the property correctly is the secret to tax success. We know how to set things up correctly from the start.Learn More
Trusts can act as a firewall against the US tax system, but are hard to do right. We create, terminate, and fix trusts.Learn More
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.
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
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.
This week’s newsletter topic comes from a previous client’s question:
... continue reading
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.
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.
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
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.
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
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.
I received the following question from reader S after writing about the Net Investment Income Tax in the context of PFIC distributions:
... continue reading
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?