Let’s Have a Conversation +1 (626) 689-0060


Recent Articles

"Own" is Such a Difficult Word

Phil Hodgen April 28, 2023

Form 5471 is hard because, among other reasons, you have to figure out the meaning of the word "own." There's your understanding of the word....

Subpart F Income: An Overview

Phil Hodgen March 17, 2023

Introduction We have default assumptions about everything. "Unless proven otherwise, X is true." For U.S. taxpayers who own stock of controlled foreign corporations, the default...

Why Form 5471 Exists

Phil Hodgen February 17, 2023

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...

Super Short Covered Expatriate Status Check

Phil Hodgen July 11, 2022

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...

Net Worth Test Q&A

Debra Rudd January 22, 2021

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...