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Category: American Business Abroad

Why Form 5471 Exists

Phil Hodgen February 17, 2023

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...

Why a Section 962 Statement is Necessary

Phil Hodgen April 21, 2020

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....

Latest developments (and Killspencer)

Phil Hodgen December 25, 2015

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...

International Tax Planning Comes Third

Phil Hodgen September 13, 2013

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...

Apple, $82 Billion of Cash, and Tax Policy

Phil Hodgen January 13, 2012

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...