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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
August 2, 2016 - Phil Hodgen

What is a “Significant” Change in Net Worth?

Hello again from Phil Hodgen. This is the biweekly Expatriation Only newsletter, which is all about . . . expatriation!

You signed up for this extravaganza — I never add people to the list, because I hate getting spam so I figure you do, too. You can easily unsubscribe by clicking the link at the bottom of this email.

This week: what is a “significant change”?

This week’s question is from reader V, who emailed me and asked about reporting significant changes in net worth for Form 8854 purposes. Edited heavily to obscure personal facts:

Thanks, once again, for your incredibly useful thoughts.

... continue reading
Expatriation
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
Expatriation 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.

... continue reading
Friday Edition