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May 19, 2016 - Haoshen Zhong

What happens when you set up an IP licensing subsidiary

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”. To browse our other newsletters, go to hodgen.com/newsletters.

What happens when you set up an IP licensing subsidiary

This week’s newsletter topic comes from a previous client’s question:

I own 40% of a BVI corporation, and a nonresident alien owns the other 60%. The BVI corporation owns an operating corporation in country X that runs a website which makes money from subscriptions for web services.

... continue reading
American Business Abroad PFIC and CFCs
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
March 10, 2016 - Haoshen Zhong

Is this a PFIC? Part II: Income Test and Asset Test

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”. To browse our other newsletters, go to hodgen.com/newsletters.

Do we have a foreign corporation?

This week’s newsletter is part 2 of a 2 part series inspired by the following question from a reader I will call Q:

I have shares in a UK investment club. It invests in UK breweries. I think it is a PFIC. How do I determine if it is one??

... continue reading
American Business Abroad PFIC and CFCs
February 25, 2016 - Haoshen Zhong

Is this a PFIC? Part I: Foreign corporation or not

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”. To browse our other newsletters, go to hodgen.com/newsletters.

Do we have a foreign corporation?

This week’s newsletter is part 1 of a 2 part series inspired by the following question from a reader I will call Q:

I have shares in a UK investment club. It invests in UK breweries. I think it is a PFIC. How do I determine if it is one??

... continue reading
American Business Abroad PFIC and CFCs
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 hodgen.com/newsletters.

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