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March 18, 2018 - Phil Hodgen

Upcoming Section 965 Workshop and a Collection of Links

The Tax Cuts and Jobs Act completely rewrote Section 965 to force a one-time repatriation of deferred earnings and profits in foreign corporations. It forces income recognition in the 2017 tax year, so there is not a lot of time to figure this one out!

Rufus Rhoades will give a one-hour free workshop on March 23, 2018 at 9:00 am Pacific Time. Register here; it’s free.

I call this a workshop because the intention is for Rufus to talk a bit about the new law, then we will open it up for questions and input. Some of you out there are smart about Section 965, so please share with us.... continue reading

American Business Abroad Minimultinationals PFIC and CFCs Speeches, Publications, and Events
March 23, 2016 - Phil Hodgen

Transfer Pricing for Business Owners (Not Tax Geeks)

Hello again from Phil, and welcome to the Friday Edition. Every other Friday you get an international tax topic – sometimes a deep dive, sometimes a breezy overview. You can stop getting these emails by clicking on the Unsubscribe link at the bottom of the email.

This week I am going to do something different. I will tackle a difficult international tax topic with a self-imposed constraint: no tax jargon will be used, except to tell you the topic. (“Transfer Pricing”.)

If Shakespeare had iambic pentameter to use as a framework, well, I can live with plain English words, ideally with three or fewer syllables.... continue reading

American Business Abroad Friday Edition
February 11, 2016 - Debra Rudd

Applying the look through rules to figure out if you have PFIC

Hello from Debra Rudd.

You are receiving this email because you are signed up for our PFICs Only newsletter, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom and click “unsubscribe”. To see what other newsletters we offer, go to

Applying the look through rules to figure out if you have a PFIC

This week I will take a look at the following anonymous question I received:

I have shares in a foreign family holding company which buys shares in various foreign businesses. I am not sure if it is a PFIC.

... continue reading
American Business Abroad PFIC and CFCs
December 25, 2015 - Phil Hodgen

Latest developments (and Killspencer)

Hi, it’s Phil Hodgen. Merry Christmas. (And no, I am not writing this on Christmas Day.)

This is the biweekly Friday Edition, chock-full of international tax goodness. You signed up for this newsletter, but if you want to stop getting it, no problem — just click the Unsubscribe link at the bottom of the email.

Next International Tax Lunch

January 8, 2016 — our regular monthly International Tax Lunch series returns after the Christmas break. Noon, Pacific time. In person or dial in.

I will be doing one hour on the foreign earned income exclusion and how to prepare Form 2555.... continue reading

American Business Abroad Foreign Business Activities in the USA Friday Edition
October 13, 2015 - Phil Hodgen

The “good bookkeeping is more important than good tax lawyering” edition

Hey everyone, it is the “every once in a while” fatigue-driven Jell-O Shot from Phil again. If I have half a brain cell and I’m sitting at an airport, you’ll get one of these.

This time I’m sitting in the KAL lounge at LAX. Flight time is 1:00 a.m. Tuesday morning: Los Angeles to Bangkok via Shanghai. Ouch. “1:00 am” and “Tuesday morning” somehow sound wrong when you put them side by side.

My wife is coming with me this time. She is on the hunt for inventory for her clothing company. Trips like this can get lonely and it’s great to have her along to share the jet lag with!... continue reading

American Business Abroad Americans Living Abroad Jell-O Shots