Estate planning for Americans abroad

A recent inquiry came in by email. Let’s call the corresondent by his initials. RH is a U.S. citizen, married to a non-U.S. citizen. They live in Australia. He and his wife have assets and retirement accounts in the United States and Australia. RH and his wife are thinking about estate planning. It’s a complex […]

PFIC to CFC transition miniseries #2 – Deemed sale election

Hello from Debra Rudd. This is a weekly newsletter devoted entirely to passive foreign investment companies, sent out every Thursday at 6:00am Pacific time. If you would like to unsubscribe from PFICs Only, please click the unsubscribe link at the bottom of this message. If you want to check out our other newsletters, please visit […]

Foreign holding companies and check the box

Hi, it’s Phil. This week’s episode was inspired by an email from reader N in France, and was written on the grassy field in front of the Rose Bowl in beautiful Pasadena, California. It is a glorious Thursday evening. My youngest daughter’s soccer team is going through conditioning drills and I’m sitting on the grass […]

PFICs to CFCs transition miniseries #1 – Triggering CFC status by buying into a foreign corporation

Hello from Debra Rudd. This is a weekly newsletter devoted entirely to passive foreign investment companies, sent out every Thursday at 6:00am Pacific time. If you would like to unsubscribe from PFICs Only, please click the unsubscribe link at the bottom of this message. If you want to check out our other newsletters, please visit […]

Green card + treaty election = exit tax danger

Hi, it’s Phil again. You subscribed to the Expatriation mailing list, sent out every Tuesday morning at 6 am Pacific time. If you want to get yourself off this list, just hit the “unsubscribe” link at the bottom of this email. However, if you’re dying to read more esoteric international tax stuff, subscribe to one […]

US real estate miniseries #4 – foreign corporation plus income tax treaty

Hi, it’s Phil Hodgen again. Welcome again to the Friday Edition. This episode is written from seat 3E on American Airlines flight 126 — LAX to Chicago. Wifi in the sky for the win, right? (Also: Bose noise-cancelling earbuds are essential for flying sanity and preventing the post-flight head-buzz from all of the engine noise. […]

What is the annual reporting requirement for PFICs?

Hello from Debra Rudd. This email is another issue of our PFICs Only mailing list — a weekly publication delivered to your email inbox every Thursday at 6:00am Pacific Time. If you don’t want to receive this newsletter anymore, feel free to cancel your subscription by clicking “unsubscribe” at the bottom of the message. If […]

Do the right paperwork to abandon your green card

Hello again from Phil Hodgen. You signed up for my “Expatriation Only” email list. To stop receiving these emails, just click the “unsubscribe” link at the bottom of this email and you will never get another one of these. If you want more of this kind of email from me, sign up for one of […]

US real estate miniseries #3 – foreign parent, domestic subsidiary

Hi, it’s Phil Hodgen again. Welcome to the Friday Edition. If you want to stop getting this thing every Friday, just click the “unsubscribe” link at the bottom of this email. I won’t be offended. On the other hand, if you want more emails like this, you can sign up for one of our other […]

How does the MTM election work during and after the OVDP?

Greetings from Debra Rudd. You are receiving this email because you signed up for our weekly PFICs Only newsletter. If you would like to cancel the subscription, please click “unsubscribe” at the bottom of this message. If you would like to receive more of these types of communications from us, go to hodgen.com/lists to sign […]