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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
April 29, 2016 - Phil Hodgen

Cloud Computing Taxation for Minimultinationals

Hi, Phil here again. Welcome to the Friday Edition. Every other week you get international tax stuff. When I am on a plane, you get a Jell-O Shot. (No plane rides for me, at least for a while. Too much year-end school stuff with the kids).

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Cloud Computing and International Tax

This episode is for people who own and run software companies – specifically, cloud-based companies: Platform-as-a-Service, Software-as-a-Service, etc. Mailchimp, the company that delivers the Friday Edition to you, is a perfect example of this kind of business.... continue reading

Friday Edition
April 26, 2016 - Phil Hodgen

IRA Distributions for Noncovered Expatriates

Hello from Phil again, and welcome to this edition of the Expatration Only newsletter.

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IRA Distributions to Noncovered Expatriates

Many people have Individual Retirement Accounts when they expatriate. This time, I will talk about how to handle IRA distributions after expatriation – for noncovered expatriates. The prompt came from reader LC, who emailed me a question. Lightly edited (to hide personally-identifiable facts), this is what LC sent me:

I currently live in [country with no income tax and no income tax treaty with the USA].

... continue reading
Expatriation
April 21, 2016 - Debra Rudd

PFIC distributions 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 distributions and Net Investment Income Tax

​Today I’m going to talk about a question I’ve received from a few different people. This particular version of the question comes from reader X:

Does the Net Investment Income Tax apply to the entire distribution I receive from my PFIC?

... continue reading
PFIC and CFCs