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September 22, 2016 - Haoshen Zhong

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
PFIC and CFCs
September 14, 2016 - Phil Hodgen

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

Expatriation
September 8, 2016 - Haoshen Zhong

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

PFIC and CFCs
August 25, 2016 - Haoshen Zhong

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
PFIC and CFCs
August 24, 2016 - Phil Hodgen

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

Nonresidents with US Activities Random