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September 16, 2013 - Phil Hodgen


“Simplicity is hard work. But, there’s a huge payoff. The person who has a genuinely simpler system – a system made out of genuinely simple parts, is going to be able to affect the greatest change with the least work. He’s going to kick your ass. He’s gonna spend more time simplifying things up front and in the long haul he’s gonna wipe the plate with you because he’ll have that ability to change things when you’re struggling to push elephants around.”

— Rich Hickey, Creator of the Clojure programming language

See Rich Hickey’s Rails Conf 2012 Keynote Speech. (YouTube).... continue reading

American Business Abroad Foreign Business Activities in the USA
September 13, 2013 - Phil Hodgen

International Tax Planning Comes Third

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 the same tax rules that Apple, Google, and Ford face.  But they don’t have the budget to deal with the legal and accounting costs that those highly complex rules will trigger.  And more importantly, they cannot afford the opportunity cost—top management will spend too much time wrestling with tax problems, and not enough time running the business.

Let’s call these companies mini-multinationals.  Multinational because they do business in more than one country, and mini because they aren’t huge, whatever your definition of “huge” may be. ... continue reading

American Business Abroad
April 27, 2012 - Phil Hodgen

Oh, what a tangled web we weave (Subpart F edition)

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 cite-checking and editing for a friend’s international tax treatise and as a result I have been living in Subpart F recently.

Two interesting points here.

Subpart F + Subpart G = Subpart F

The first is of interest to tax lawyers only. When we say “Subpart F” we are wrong. The subject matter is actually contained in Subpart F and Subpart G. I never realized this until last night, while perusing a footnote.

Start with a lie .... continue reading
American Business Abroad
January 13, 2012 - Phil Hodgen

Apple, $82 Billion of Cash, and Tax Policy

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 of Unintended Consequences.  (That, by the way, is a demonstration of the fabulosity of the interwebs.  Hyperlinks and attributions back to the source.  The internet is just one person talking to another.)

Back to tax policy and unintended consequences.  This stuff is right up my alley because this type of tax planning is What We Do here at the Hodgen Law Group Tax Ranch & Rocket Factory.

Put this blog post under the heading of “Unintended Consequences of International Tax Policy.”... continue reading

American Business Abroad
August 28, 2011 - Phil Hodgen

List of international tax forms (first draft)


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 California Society of CPAs. It will be presented in Universal City, San Francisco, and on the web.

My hour is intended to give practitioners a checklist approach to the various tax and reporting forms they might need to know about in the international context. For someone who deals primarily with domestic stuff, the international world is a mystery. I want to dispel that mystery a bit.

First draft of a list

Here, from my course materials for my Tax Planning and Compliance for Multinational Families course is where I am in gathering a comprehensive list of all of the tax forms that are specific to international tax practice.... continue reading

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