Menu

Blog

RSS
June 1, 2016 - Haoshen Zhong

PFIC Look-through for Foreign Pensions

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 annually report PFICs held in a UK pension scheme?

This week’s newsletter topic came by way of a reader I will refer to as Vic:

We see a lot of UK employer funded pension schemes are heavily invested in PFICs – most UK pension schemes fall into this category.

... continue reading
PFIC and CFCs
May 27, 2016 - Phil Hodgen

Double-Dog Dare DAO Token Taxation Discussion (DDDDTTD)

Hey everyone, welcome again to the Friday Edition from Phil Hodgen. You subscribed to this, but you can easily stop it from coming. Just click the “unsubscribe” link at the bottom of this email. We have four other newsletters, too. Go to http://hodgen.com/newsletters to sign up if you want more international tax stuff in your life.

This episode is different. It is the Double-Dog Dare DAO Token Tax Discussion. DDDDTTD.1

After a dare – a double-dog dare – to do so from Edmund at flagtheory.com, I took a look at the tax treatment of DAO tokens. Hey, Edmund.... continue reading

Friday Edition
May 24, 2016 - Phil Hodgen

The Dual Citizen Exception to Covered Expatriate Status

Hello everyone. It’s Phil Hodgen, and welcome to Expatriation Only, the email newsletter that I send out every other Tuesday.

If you want to unsubscribe from this list, just click the “unsubscribe” link at the bottom of the email.

Dual Citizen Exception

This week, let’s look at the dual citizen exception to covered expatriate status.

When you renounce your U.S. citizenship, you will be characterized as a “covered expatriate” — or not. It is better to not be a covered expatriate. Covered expatriates will probably pay some tax for the privilege of leaving the U.S. tax system behind them.

There are three reasons why you would be characterized as a “covered expatriate”.... continue reading

Expatriation
May 19, 2016 - Haoshen Zhong

What happens when you set up an IP licensing subsidiary

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.

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