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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

Uncategorized
August 19, 2016 - Phil Hodgen

Nonresidents Buying U.S. Hedge Funds: How it Works

Hello again and welcome to the Friday Edition. Every other Friday, you get some international tax . . . ermmm . . . stuff from me, Phil Hodgen. You subscribed, so don’t blame me. 🙂

You can easily unsubscribe if you want — just click the unsubscribe link below.

Or, why don’t you live dangerously and forward this email to a friend?

I welcome new subscribers — and comments/criticisms/questions from readers. (Just hit “reply” and your email will come straight to me.)

Too Long; Didn’t Read

In a hurry?

  • U.S. income tax results are great for most hedge fund investments made by nonresidents.
... continue reading
Friday Edition
August 16, 2016 - Phil Hodgen

Installment Agreements and Covered Expatriate Status

Hello again from Phil Hodgen. This is the biweekly Expatriation newsletter, in which we talk about the U.S. tax ramifications of giving up U.S. citizenship or permanent residence status.

If you do not want to get this anymore, just click the “unsubscribe” link at the bottom of the page.

On the other hand, if you would forward this to a friend, I would appreciate it mightily. New subscribers.

By the way. If you have a question for me, just shoot me an email. Hit “reply” and start typing. I am always looking for good newsletter topics.

The Certification Test and Installment Agreements

This newsletter is about the certification test.... continue reading

Expatriation
August 11, 2016 - Haoshen Zhong

Reinvested Dividends from 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.

Have I received a distribution if a PFIC reinvests a dividend?

This week’s newsletter came by way of a CPA I will call GW.

if a dividend from a PFIC is not paid to the holder of the PFIC, but is reinvested in the fund, does this constitute a ‘distribution’ for the purposes of the excess distribution section 1291 rules under the Code?

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

Avoiding Banking Problems with Corporate Reorganizations

Hello again, and welcome to the Friday Edition. More international tax goodies this Friday and every other Friday.

It's Phil Hodgen and you signed up for this road trip. (I never add people to the mailing list — I hate getting spam and I will not inflict it on others). If you want to stop getting this, there is an unsubscribe link at the bottom of this email that will do the trick.

Nonresident Seller and No U.S. Bank Account

This week's episode is for nonresident investors in U.S. real estate. Specifically, I am going to talk about an expedient method I have used before (and will use again) to get around a banking problem.... continue reading

Friday Edition