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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
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