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May 19, 2016 - Haoshen Zhong

What happens when you set up an IP licensing subsidiary

Greetings from Haoshen Zhong.

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What happens when you set up an IP licensing subsidiary

This week’s newsletter topic comes from a previous client’s question:

I own 40% of a BVI corporation, and a nonresident alien owns the other 60%. The BVI corporation owns an operating corporation in country X that runs a website which makes money from subscriptions for web services.

... continue reading
PFIC and CFCs
May 13, 2016 - Phil Hodgen

When Americans Can’t Own Real Estate Abroad

Hello from Phil and welcome again to the Friday Edition. Every other Friday you get your dose of international tax news from me. If you want this email to stop, please click the “unsubscribe” link at the bottom of the email.

When Americans Can’t Own Real Estate Abroad

Many countries will not allow foreigners to own real estate. Mexico is a prominent partial example for Americans — direct real estate ownership is forbidden for property too close to the border or the coastline. Inland, no problem. Other countries flatly limit ownership of real estate to their citizens only.

I received a WhatsApp message from an American living in one such country.... continue reading

Friday Edition
May 10, 2016 - Phil Hodgen

Tax Residency Starting, Termination Dates for Green Card Holders

Hey there fellow expatriation aficionados. Phil here with the every-other-Tuesday Expatriation Only newsletter.

You can unsubscribe by clicking the “unsubscribe” link at the bottom of this email.

Simple Facts Meet Dumb Systems

This week is not a strictly an expatriation topic. The person who wrote to me is a newly-minted green card holder who intends to abandon his permanent resident status after 2.5 months in the USA.

He will not be a “long-term resident” and therefore the expatriation rules will not apply to him. What WILL apply to him, however, are the tax return filing rules. In a nutshell, someone with a fleeting presence in the United States faces a requirement to file U.S.... continue reading

Expatriation
May 5, 2016 - Debra Rudd

PFIC deemed sale gains and Net Investment Income Tax

Hi from Debra Rudd.

​You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom and click “unsubscribe”. To see what other newsletters we offer, go to hodgen.com/newsletters.​

PFIC deemed sale gains and Net Investment Income Tax

I received the following question from reader S after writing about the Net Investment Income Tax in the context of PFIC distributions:​

Along the same lines, if you were doing a deemed sale to remove the PFIC taint, would the gain from the sale still be subject to the NIIT?

... continue reading
PFIC and CFCs
May 5, 2016 - Phil Hodgen

That quarterly published of expatriates – an anecdote

The U.S. government publishes a quarterly list of expatriates (by name), presumably for reasons derived from this country’s Puritan roots.  (I kid, I kid!)  

People often wonder if the list is complete.  Well, who knows.  We can all doff our tin-foil hats for a moment and debate whether the list is selectively curated by the bureaucrats who have the job.

What is undeniable, however, is that there is delay.

A report from the field, from someone I know (published with permission):

As a point of interest, as I am sure you know there are many blogs, etc on the net about just who gets published (quarterly) by the Gov after they expatriate.

... continue reading
Expatriation