October 25, 2016 - Phil Hodgen

How to be a Resident After You Renounce

Welcome to Expatriation Only, the biweekly newsletter about giving up U.S. citizenship and residence.

Please subscribe to our other newsletters, at

Promoting Our Brand New Newsletter: Supers Only

We have a brand new newsletter: Supers Only. It is a companion to our newest website,, currently in soft launch.

The subject? Australian superannuations – the Australian pension plan.

The audience? We are publishing the newsletter for Americans living and working in Australia, and Australians living in the United States. These two groups have a non-obvious U.S. tax problem, and it needs fixing.

The problem? The U.S.... continue reading

October 18, 2016 - Haoshen Zhong

Why a Holding Company for Active Businesses is Probably Not a PFIC

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”.

Superannuation Newsletter

We are launching a new bi-weekly newsletter dedicated to superannuations, starting Wednesday, October 26, 2016. We will be making posts regularly on its dedicated website (coming soon) weekly on Monday, Wednesdays, and Fridays.

Please sign up for the newsletter at to learn how to solve superannuation tax problems, and to receive the announcement that the new website has been launched.... continue reading

October 14, 2016 - Phil Hodgen

Everyone Has a Plan ‘Til They Get Punched in the Mouth

Welcome to The Friday Edition, the biweekly newsletter on international tax things, because, well, that’s what I do in my day job.

This episode is for people who are aware that they have a tax problem. You might be running a business and know that there are a lot of unfiled forms (Form 5471 is a favorite) you need to take care of. Or you might not have filed tax returns for years. Or you earned income but did not report it for taxes.

In one way or another you have reached the jumping-off point. You have realized there is a problem, and you need to solve it.... continue reading

Friday Edition
October 11, 2016 - Phil Hodgen

Easy Math for Determining Long-Term Resident Status

Hello and welcome to Expatriation Only, the biweekly newsletter that focuses on people renouncing U.S. citizenship or giving up green cards.

This week’s edition was triggered by a query from a reader, who was unclear about how green card holders figured out whether the exit tax rules applied to them (or not).

The exit tax rules apply to expatriates. Citizens become expatriates by relinquishing U.S. citizenship. Immigrants become expatriates by (1) being immigrants for a long time, then (2) giving up their immigrant visa status.

Immigrants who hold their permanent resident visas (green cards) for long enough to be hit by the exit tax are called long-term residents.... continue reading

October 6, 2016 - Phil Hodgen

Hear Atossa Abrahamian Speak About Buying and Selling Citizenship

There is a booming trade in selling citizenship and permanent resident status as a path to citizenship. People think that only small countries do this. While small countries do sell passports (St. Kitts is a prominent example), large countries do this as well. Even the United States, under the guise of the EB-5 “buy a green card” program, provides a path to American citizenship for the well-to-do.

We are seeing the rise of a new type of person–the multinational individual. Tax professionals have long known how to deal with multinational business operations, but now we are confronted with the same high level of multi-country tax complexity, applied to people.... continue reading

Speeches, Publications, and Events