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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...

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...

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....

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...

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...

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...

Hello again from Phil, and welcome to the Friday Edition. Every other Friday you get an international tax topic – sometimes a deep dive, sometimes...

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...

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...

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...

I received an email via Hackernews and figured I would answer it here, because this is a common question. This is likely to be the...

Tax planning across borders is complicated.  A massive public company has the budget to deal with complex international tax problems.  Privately-held businesses must deal with...

Oh what a tangled web we weave, When first we practise to deceive! Sir Walter Scott, Marmion, Canto vi. Stanza 17 I have been doing...

Via Glenn Reynolds I was pointed to a TUAW article that referenced a SeekingAlpha article about Apple, its mythical mountain of cash, and the Law...

  Upcoming speech I am going to be giving a one-hour high speed presentation at the 2011 Tax Update and Planning Conference sponsored by the...