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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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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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August 25, 2016

Is my Personal Service Company 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”. To browse our other newsletters, go to hodgen.com/newsletters.

Is my personal service company a PFIC?

This week’s newsletter topic came by way of a CPA I will call SL.

I have a client who is a US citizen and a physician, running a practice through a Canadian corporation. She owns 50% of the shares of the corporation, and her brother owns the other 50%.

... continue reading
August 24, 2016

Why Tax Practitioners Cannot Cash Your Refund Check

People who file Form 1040NR (as nonresidents of the United States) will sometimes receive a tax refund.  Sometimes it is large, sometimes it is small.

The IRS, by default, issues a paper check for refunds.

It will shock you to discover that sometimes paper checks take a long time to reach their overseas destination.  Sometimes the paper checks never arrive.  Or sometimes it is a big hassle to deposit the U.S. dollar denominated check into a bank account overseas.  Or it costs a significant amount in bank fees to get this done.

In short, paper checks are an abomination.

It is possible to have refunds deposited directly to your bank account.... continue reading

August 19, 2016

Nonresidents Buying U.S. Hedge Funds: How it Works

Hello again and welcome to the Friday Edition. Every other Friday, you get some international tax . . . ermmm . . . stuff from me, Phil Hodgen. You subscribed, so don’t blame me. 🙂

You can easily unsubscribe if you want — just click the unsubscribe link below.

Or, why don’t you live dangerously and forward this email to a friend?

I welcome new subscribers — and comments/criticisms/questions from readers. (Just hit “reply” and your email will come straight to me.)

Too Long; Didn’t Read

In a hurry?

  • U.S. income tax results are great for most hedge fund investments made by nonresidents.
... continue reading
August 16, 2016

Installment Agreements and Covered Expatriate Status

Hello again from Phil Hodgen. This is the biweekly Expatriation newsletter, in which we talk about the U.S. tax ramifications of giving up U.S. citizenship or permanent residence status.

If you do not want to get this anymore, just click the “unsubscribe” link at the bottom of the page.

On the other hand, if you would forward this to a friend, I would appreciate it mightily. New subscribers.

By the way. If you have a question for me, just shoot me an email. Hit “reply” and start typing. I am always looking for good newsletter topics.

The Certification Test and Installment Agreements

This newsletter is about the certification test.... continue reading

August 11, 2016

Reinvested Dividends from 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”. To browse our other newsletters, go to hodgen.com/newsletters.

Have I received a distribution if a PFIC reinvests a dividend?

This week’s newsletter came by way of a CPA I will call GW.

if a dividend from a PFIC is not paid to the holder of the PFIC, but is reinvested in the fund, does this constitute a ‘distribution’ for the purposes of the excess distribution section 1291 rules under the Code?

... continue reading
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Events

Featured Event

CalCPA: Foreign Trust Series

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

Where: Webcast hosted by CALCPA

Foreign Trusts: The Basics
Presenter: 
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

September: International Tax Lunch

Who: Debra Rudd

When: September 9th, 2016 at 12:00PM PDT

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