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

Real Estate

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

Learn More

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.

Learn More


June 24, 2016

Trust Structures for Nonresident Real Estate Investors

Nongrantor trusts offer excellent tax performance for nonresident investors in U.S. real estate:

  • Estate tax risk is eliminated; and
  • Long term capital gains tax treatment applies to capital gains.

But everything has its price. These excellent tax results come at the expense of:

  • Significant set-up costs.
  • Significant operating costs.
  • Loss of control.
  • Capital — and capital gain — no longer belong to the investor.
Shameless Promotion: More on July 8, 2016

This episode of the Friday Edition gives you an overview of the benefits and risks. If you want more detail, you might consider an upcoming webcast/phone presentation on the topic.... continue reading

June 13, 2016

Lookthrough rules for mutual funds held in nonqualified foreign pensions

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

Do I have to report PFICs held in an employer matching pension?

This week’s newsletter is a question we get frequently:

I have a US citizen client who is living and working in Hong Kong. The employer provides a retirement plan where the employee contributes, and the employer matches some percent of the employee contributions.

... continue reading
June 10, 2016

My correspondents make me jealous

I traded emails earlier this morning with a tax lawyer friend who happens to be in Istanbul right now.  This is the view from his balcony.  I am deeply jealous.


... continue reading

June 10, 2016

Pooled Capital for Real Estate Investments by Nonresidents

Holding Structures for Pooled Nonresident Real Estate Investment

A group of nonresident individuals want to pool their money to buy commercial real estate in the United States.

They are going to buy decent-sized properties — commercial and office properties in the $5 million to $50 million range. This is serious money but not crazy huge.

How should they set this up for optimum U.S. tax results?

The Factors to Consider

The factors to consider are:

  • Estate tax. People die, and when they do, the Internal Revenue Service looks around to see if there are any assets can be taxed. Nonresident individual investors can — and should — eliminate that estate tax risk.
... continue reading
June 7, 2016

A Quick Overview of the Exit Tax

Hi, it’s Phil. I’m going to change up the Expatriation Newsletter for a while. It’s time to write up everything I know about the exit tax. Over the next few months I will be publishing the chapters on a regular schedule.

You can find the updated Chapter 1: A Quick Overview of the Exit Tax here.


 ... continue reading

Read Our Blog


Get the Newsletter

Join more than 3000 subscribers to get weekly information on your international tax obligations, plus the intermittent jet-lagged missives from an airport lounge somewhere.

Subscribe Now


Featured Event

CalCPA: U.S. Real Estate Series

When: July 13, 2016 8:30AM to 12:30PM PDT

Where: Webcast hosted by CalCPA

Acquisition of U.S. Real Estate by Nonresidents: Selecting the Holding Structure
: Haoshen Zhong
Time: 8:30 AM – 9:30 AM
Nonresidents who acquire U.S.

International Tax Lunch

July: International Tax Lunch

How To Use Nongrantor Trust Structures For Foreign Investment In U.S. Real Estate

Nongrantor trusts (foreign or domestic) have significant tax advantages for foreign investors in U.S.

See All Events