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Expatriation

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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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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September 27, 2016

When Should You Choose to be a Covered Expatriate?

Hi, it’s Phil. Welcome once again to Expatriation Tuesday, the biweekly newsletter that is all about the tax effects of renouncing U.S. citizenship — or giving up a green card.

This time, let’s talk about why you might want to deliberately be a covered expatriate. For some people, it is a tax-saving strategy.

Success = Basis Step-Up Without Tax

If you do this right, you can, by deliberately being a covered expatriate, harvest some capital gain on your real estate — tax-free. Put another way, you can achieve a step-up in basis of your U.S. assets, tax-free.

Who Should Think About This

The conditions for using this strategy are:

  1. You do not have big IRA balances or foreign pensions;
  2. You have U.S.
... continue reading
September 22, 2016

Are Stapled Securities One or More Than One Corporation?

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.

Stapled securities

This week’s newsletter topic is a question that came by way of an email:

I frequently see stapled securities, where one part is a share in a corporation that receives nonpassive income and another is a unit in a unit trust that receives passive income. Is this one share in a corporation or two separate shares in two corporations, one of which is a PFIC?

... continue reading
September 14, 2016

This Week: Planning for the Exit

Hello again from Phil and welcome to the biweekly Expatriation Only newsletter. Subscribe to our other newsletters at hodgen.com/newsletters.

This Week: Planning For the Exit

This week’s topic was triggered by an email from reader J., received a few weeks ago. She wanted to know how a 20+ year green card holder should plan for giving up permanent resident visa status and leaving the United States.

Here is a high-level view of our S.O.P. for helping people exit the United States. Bear in mind that each situation is slightly different, so just treat this as a high-level map of the terrain.... continue reading

September 8, 2016

Shortcuts We Use to Determine if an Investment is 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.

Shortcuts for determining PFIC status

This week’s newsletter topic is a question we get quite often:

I have a large number of investments in foreign funds and companies. Is there any way to tell whether they are PFICs without checking their income and assets?

In this newsletter, I will talk about the shortcuts we use to determine PFIC status when we encounter a client with a lot of different foreign investments.... continue reading

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
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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

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.  

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