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November 14, 2016 - Phil Hodgen

ACA Solves Banking Problems for Americans Abroad

Americans living abroad have a hard time keeping U.S. bank accounts open.  As soon as the bank (or investment firm *cough* Merrill Lynch *cough*) finds out you are living abroad, you are apt to get your account closed.  

Subterfuge is a common solution.  (Subterfuge is an $11 word that means “tell the bank a lie”.)  You simply report that you have a home address in the United States.  That address happens to be the home of a friendly friend, parent, or sibling.

Now you can do it correctly, courtesy of American Citizens Abroad.

For Americans living abroad, opening and maintaining a US bank account has been a BIG problem.

... continue reading
Americans Living Abroad
November 14, 2016 - Phil Hodgen

NYSSCPA International Tax Conference, 26 January 2017 – I’m speaking about expatriation

Just a heads-up (and shameless promotion) for this upcoming event.  

I am giving a presentation at the New York State Society of Certified Public Accountants’ International Tax Conference on January 26, 2017.  

The topic is expatriation.

Sign up to attend in person or livestreamed on the web.

And many thanks to the Committee (and especially Susan Brown Otto) for inviting me.

I will be in New York for a few extra days, in the name of fun, etc.  My wife is coming with me on this trip.  🙂  She lived in Manhattan for 15 years before moving to California (where I met her) so she takes every opportunity she can to return to NYC.... continue reading

Speeches, Publications, and Events
November 11, 2016 - Phil Hodgen

Liftoff for a Multinational Business Structure

Let’s talk about how you go from I want to start a business to customers are giving me money. Well, we will talk about the part where you decide on a business structure, do tax planning, and set the whole thing up.

A legal structure for a business is, among other things, plumbing. It’s all buckets and pipes. Money flows through the pipes and sits in the buckets. Your objective is to get money from the customer (at one end of the system) and into the pocket of the owner (at the other end of the system) with as little leakage as possible.... continue reading

Friday Edition
November 11, 2016 - Phil Hodgen

Tax Planning and Compliance for Multinational Families – 02 Dec 2016

I just received the reviews from my October 26, 2016 all-day course for CalCPA, “Tax Planning and Compliance for Multinational Families.”  This comment made me happy:

Easygoing, unpretentious and knows his stuff…

If you want to attend, I will be presenting the course live in San Francisco on December 2, 2016.  This event will also be webcast live on December 2.

Eight hours of glorious CPE/MCLE credits. Get ‘em while they’re hot.

Sign up on the CalCPA website.... continue reading

Speeches, Publications, and Events
November 8, 2016 - Phil Hodgen

Death and Taxes and Expatriation

I have not really focused on the estate tax side of expatriation in any great depth. This will be the first of several blog posts where you get 26 U.S.C. §877A and §2801 stuff every two weeks. Plus other bonus coverage of other §§ of the Internal Revenue Code.1

Why IRC Section2 2801 Exists

This week let’s talk about the unheralded PITA embedded in the tax rules that haunt covered expatriates.

U.S. persons who receive gifts or inheritances from covered expatriates will have the privilege of paying $0.40 of every dollar they receive as punishment for having been acquainted with someone who renounced U.S.... continue reading

Expatriation