Blog

The Scenario A nonresident owns 100% of the stock of a foreign corporation, which holds highly appreciated foreign real estate. Real estate FMV $4,000x, basis...

This article looks at Category 2 filers. These are United States persons serving as officers and directors of foreign corporations. The lesson of this post...

Form 5471 exists because Subpart F (IRC §§951-965) exists. Or to be more precise, Form 5471 exists because Subpart F exists and taxpayers are smarter...

One favorite way to wiggle out of any responsibility is to mooch off someone else's hard work. Form 5471 filing is no exception. Go look...

Legal Authority This method of joint filing for Category 2 filers is described in Reg. §1.6046-1(e)(3). Introduction Start With the Filing Requirement Trigger Start with...

You’re right but why are you right? A lot of the things you just “know” are right. But you don’t know why you’re right. This...

This blog post describes a situation when there is an exception in the attribution rules so that one spouse is not considered the owner of...

General Information about "Covered Expatriate" Status There are three triggers that can cause you to be a covered expatriate. You only need one to be...

This post is a collection of questions and answers from Debra Rudd’s February 12, 2021 International Tax Lunch webinar on Asset Taxation During and After...

This post is a collection of questions and answers from Debra Rudd’s January 15, 2021 International Tax Lunch webinar on the Net Worth Test. The...

Here is a simple explanation of "tested interest expense" -- one of the variables you will compute when calculating how much global intangible low-taxed income...

On July 10, 2020 I will  present a live Section 962 webcast that goes into excruciatingly painful detail about preparing a Section 962 tax return....

When you expatriate, you are required to declare all of your assets and liabilities and compute your net worth. If your net worth is above...

In late 2017 our Trusted Servants(TM) in Congress blessed us with a new tax law. Among other features, the new law contained a spectacular Come...

I have posted the full text of this case to make it easy to cross-reference to my previous blog post discussing what happened here.  Don't...

The World’s Worst Tax Strategy “How will they ever find out?” It’s a classic tax-planning strategy that works very well, until the day it doesn’t...

Covered expatriates are subject to exit tax. For most types of assets, a pretend sale applies, and the covered expatriate must pay tax on gains...

All covered expatriates must pay exit tax. The exit tax is computed differently depending on the type of asset. Over the last two months, I...

Recently the IRS announced that it will be rolling out a compliance initiative for expatriates. There is no information about how this program will work...

The exit tax applies to everything a covered expatriate owns. The method of calculating tax, however, differs depending on the asset involved. For most types...