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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...

Last month, I explained how to determine if you are a covered or non-covered expatriate. The major difference between covered and non-covered expatriates is that...

There are two types of expatriates: covered expatriates, and non-covered expatriates. Covered expatriates must pretend that they sold all their worldwide assets on the day...

Last month, I discussed how long-term residents can become expatriates. Now I will overview the tax paperwork expatriates will need to file. All individuals who...

Introduction All of the profits generated by a minimultinational enterprise will be exposed in real time to the U.S. tax system. Chapter 2 explains why....

Last month, I talked about citizens and how they can renounce their US citizenship. This month, I am focusing on another group of people who...

Last month, we covered a general overview of the exit tax, expatriation, and the distinction between covered and non-covered expatriates. We will now focus on...

American minimultinationals are small (for various definitions of "small") business enterprises subjected to the U.S. tax system. There are many ways that a minimultinational becomes...

What's an American Minimultinational? What do I mean by American minimultinational? Multinational A multinational business operates in multiple countries, exposed to multiple tax-hungry governments. Apple....

Today’s topic: A quick overview of the exit tax The term “exit tax” is not used or defined in the Code or regulations anywhere. It...

If you are an American living abroad and sweating the October 15, 2018 tax filing deadline for your 2017 income tax returns, there is a...