We can help you cleanly exit from the US system -- we know the tax rules and have been through the process many times.Learn More
Buying the property correctly is the secret to tax success. We know how to set things up correctly from the start.Learn More
Trusts can act as a firewall against the US tax system, but are hard to do right. We create, terminate, and fix trusts.Learn More
For companies that operate across the US border, we can help with the complexity of US tax planning.Learn More
There has been a lot of ballyhoo over the last few years about mega-multinationals (like Apple and Google) and their international tax structures. The amounts of money stashed abroad are staggering. But frankly, spending time complaining about Apple and Google’s tax planning is a mug’s game — the political ideologue’s version of smugly judgmental nattering about the Kardashians.
Meanwhile, real people roam the surface of Planet Earth, living real lives. Think of a normal American citizen living abroad, running a consulting business with $1 million of revenue and $500,000 of expenses. That’s real, and his problems are worth talking about.
Our American citizen abroad is the human embodiment of a multinational business enterprise.... continue reading
I want to give you a slight detour from tax law to see a little-known Federal law that applies to U.S. citizens who renounce their nationality.
The topic is guns–former U.S. citizens cannot (legally) own them. The topic is interesting in its own right, but it is meta-interesting too:
You might not care about guns. You might be violently anti-gun (haha see what I did there?). But the propensity for ever-extending tendrils of Federal legislation might be of interest to you.... continue reading
This is a question we received through an email:
I own stock of a foreign real estate investment trust (REIT). It is a corporation under US tax law. It owns a hotel and rents rooms directly. It outsources the management of the hotel to an unrelated entity, but it has all the legal and contractual relationships with the guests.
In this post, I will discuss why this type of rental income is passive, which causes the REIT to be a passive foreign investment company (PFIC).
Passive foreign investment company (PFIC) is a specific classification under US tax law.... continue reading
I received an email this morning from a correspondent: an Enrolled Agent working outside the United States.
... continue reading
Hope all is well. My new year was off to a good start until I had to call the IRS today regarding a client matter. They asked me for my SSN or ITIN. Told them I was a nonresident alien and did not have one. They said the new policy to combat identity theft is they cannot talk to me unless I have a SSN or ITIN. The fact that I have a PTIN, a CAF number and an EIN and have been an EA since 1996 did not matter.
Self-employed people are enterprises engaged in commerce without using a business entity, like a corporation or limited liability company. Human-scale businesses can be large, and even be multinational enterprises: doing business within the grasp of multiple countries’ tax systems.
An American entrepreneur living and doing business abroad is by definition a multinational business: his country of residence and the United States both assert the right to tax him.
For purposes of demonstrating basic tax principles, let’s assume we have an American management consultant living and working in Dubai. No spy stuff, just commerce.The Taxes
An American living and working abroad is fully taxable by the United States, simply because he is a U.S.... continue reading