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July 28, 2016 - Haoshen Zhong

Lookthrough of Subsidiary when Subsidiary is Liquidated

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.

Do I create a PFIC problem during corporate reorganizations?

This week’s newsletter is a case study of one of our clients. His situation is more or less as follows:

The client is a US citizen. He holds a minority stake in a private equity fund. All other stakeholders are foreigners.

... continue reading
PFIC and CFCs
July 22, 2016 - Phil Hodgen

Former green card holder returning to the United States as a visitor

If you sign up for one of my email newsletters, you will get a bot-response from me, thanking you for signing up.  But if you ask a question, the response is remarkably lifelike, because I actually write the answer.  🙂

Today reader S.J. signed up and here is what he wanted to know.  I have edited his comments slightly for formatting and clarity, but mostly to hide identifying information.

1 – What’s the single most important question you have about international tax?

I abandoned my LPR green card in ______, 2015 (delivered my Green Card with Form I-407 to the US embassy) and was given a visitor visa.

... continue reading
Nonresidents with US Activities
July 22, 2016 - Haoshen Zhong

Withholding When You Pay a Nonresident Alien Working Outside the US

Greetings from Haoshen Zhong.

You are receiving this email because you are subscribed to our Friday Edition newsletter, delivered to your inbox every other Friday 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.

What is my withholding responsibility when I pay a nonresident alien for work outside the US?

Today’s newsletter came by way of an email question:

I hired a web designer in Nicaragua to work on my website. He put together something from his home office. He is a nonresident alien.

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Friday Edition
July 19, 2016 - Phil Hodgen

Closure After Expatriation

Hi again, and thanks for reading. It’s Phil with the every-other-week Expatriation Only email newsletter. You can unsubscribe by clicking the link at the bottom of this email.

Closure After Expatriation

This week is an answer to an email I received from a reader. It asks about what happens after you file that final income tax return.

It is a fairly common question, and there is a short, but unsatisfactory (to those of us who are a teensy bit OCD) answer.

I would like to thank you for the wealth of information you have shared in your expatriation blog. It has certainly helped me greatly in trying to work my way through the entire process.

... continue reading
Expatriation
July 12, 2016 - Haoshen Zhong

Lookthrough Rules for Mutual Funds Held in Foreign Pensions in Treaty Countries

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.

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 country X. Country X has an income tax treaty with the US. The employer provides a retirement plan where the employee contributes, and the employer matches some percent of the employee contributions.

... continue reading
PFIC and CFCs