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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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February 6, 2016

Filing and Tax Payment Deadlines for Americans Abroad

Hello and welcome to this edition of the Friday Edition. You signed up for this, but you can easily stop it from coming by clicking the “unsubscribe” link at the bottom of the email.

This time you get a little summary of the Form 1040 filing deadlines for Americans abroad. The rules are unnecessarily precious and convoluted, so this is my attempt at providing a simple explanation. It is a happy by-product of my preparation for a webcast I will be doing for the California Society of Certified Public Accountants.

What is the filing deadline for an income tax return filed by a U.S.... continue reading

February 2, 2016

Noncovered Expatriates and Superannuations

Hi, it’s Phil with the bi-weekly Expatriation Only newsletter. You have this because you subscribed, but it is easy to stop getting this if you want. Just look for the “unsubscribe” link at the bottom of this email.

Superannuations, Noncovered Expatriations, and the Stealth Exit Tax

This week’s question came from new reader Z (her real name does not start with Z), who asked a question about her superannuation. Lightly edited, her question is:

My question relates to the treatment of my Australian self-managed super fund when I expatriate. It is treated as a Grantor Trust and I get taxed on the (paper) gains on its assets each year.

... continue reading
January 28, 2016

Is a late MTM election under the inbound immigrant rules possible?

Hello from Debra Rudd.

You are receiving this email because you are signed up for our bi-weekly “PFICs Only” newsletter, delivered to your electronic mailbox every other Thursday at 6:00am Pacific time. To stop receiving this newsletter, scroll to the bottom of this email and click “unsubscribe”. On the other hand, if you would like to see the other newsletters that we offer, go to

Is a late MTM election under the inbound immigrant rules possible?

This week’s topic comes from a question I received a while ago from an anonymous reader:

Does an immigrant to the US get to apply the basis step up/transition rule if they did not do a MTM election in their first year of US residence?

... continue reading
January 22, 2016

Nonresident investors, U.S. real estate, and secrecy

Hi from Phil, and welcome to the Friday Edition. Every other week you get something about International Tax from me. And every now and then, a Jello Shot from a random airport somewhere. If you want these to stop, just click the unsubscribe link at the bottom of this email.

Nonresidents, Secrecy, and U.S. Real Estate

Your U.S. government (say that in your best reverberating sports stadium announcer’s voice, the way the guy says “Your Los Angeles Dodgers”) is on the move again.

More “transparency for thee, but not for me” stuff from Your Public Servants.

This time, it is aimed at nonresidents who buy U.S.... continue reading

January 19, 2016

No social security number; expatriate anyway?

Hi again from Phil. Welcome to the biweekly Expatriation newsletter, this time written in the lovely Al Faisaliah Hotel in Riyadh, which is being remodeled at the moment. But it’s still lovely.

If you want to stop getting this email, click on the “unsubscribe” link at the bottom of this email.

No SSN, Deliberately Be a Covered Expatriate

This time I am going to talk about the deliberate choice to be a covered expatriate. The triggering reason is usually “I do not have a Social Security Number”.

The question was triggered by an email I received a while ago:

I recently read your blog and I have a question I hope you can help me with.

... continue reading
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Featured Event

Americans Abroad: Webcast Series

On February 9, 2016, the Hodgen team will be instructing a four-part series of courses designed for tax practitioners advising U.S. taxpayers living abroad. We will cover a number of topics, including foreign retirement accounts, the foreign earned income exclusion, PFICs, and special compliance requirements.

Register Now
International Tax Lunch

February: Foreign Family Trusts

A foreign husband and a US citizen wife together own a successful family business in the foreign country.  They put their business into a discretionary family trust as part of their estate planning, and they distribute some funds from the trust to help their children.  

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