Articles The IRS translated for you

Every other Friday, we publish what we like to think is the most thoughtfully researched International Tax Newsletter in the world.

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Webinar: Portfolio Interest Real Estate Finance: Nonresident Parent Lender, U.S. Resident Child

When a Grantor Trust is a Nongrantor Trust

PFICs Inside SIPPs and Form 8621

Webinar: Foreign Retirement Plans as IRC §402(b) Employee Trusts

How IRC §402(b) Taxes an Employee on a SIPP’s Investment Earnings

Treaty Treatment of the 25% Tax-Free Distribution from a U.K. SIPP

Webinar: Pre-Residency Tax Planning

FTC against the NIIT? TBD

The Substantial Presence Test, the Closer Connection Exception, and FBAR Filing Requirements

Field Guide to UK SIPPs — U.S. Taxation of SIPP Income

Webinar: Pre-Expatriation Planning to Minimize Exit Tax

Field Guide for U.K. SIPPs: Employer Contributions

Webinar: Form 3520‑A: When to File, What to Report

What is the Taxable Year of a Foreign Grantor Trust on Form 3520‑A?

How to Determine a CFC’s Accounting Period

The §7701(b)(10) Trap: When US Residency Doesn’t End at Departure

How a Nongrantor, Nonbeneficiary of a Foreign Trust can be Required to File Form 3520

Webinar: Form 5471, Schedules J and P: Previously Taxed Earnings and Profits

Webinar: Form 3520 and May 2024 Proposed Trust Regulations: Selected Topics

Annotated Checklist for Noncovered Expatriates with Foreign Retirement Plans