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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...

If you are an American living abroad and sweating the October 15, 2018 tax filing deadline for your 2017 income tax returns, there is a...

I received an email from a practitioner this morning and figured it’s worth a blog post. Reader C in Sydney asked me: Hi Phil, Would...

Answers In a Hurry Here are the answers in a hurry: When You Must File Your Income Tax Return April 15. If your "tax home"...

Covered expatriates risk being taxed twice: once by the United States on assets they own when when they expatriate, and a second time by their...

This Tax Court Memorandum opinion is currently only available on (extremely overpriced and God-awful UI) Lexis via Tax Notes Today. (How do you take something...

We finally have sane filing deadlines for income tax returns and FBARs (FinCen Form 114). But there is still a trap for the unwary. Income...

American Digital Nomads With U.S. Corporations This article is for entrepreneurs who, for valid reasons, need to have a U.S. corporation to operate their businesses....

Green card holders living abroad can have a weird hybrid (tax) life. They are U.S. residents for income tax, but can be U.S. nonresidents for...

This discussion is for Americans working abroad who want to claim the foreign earned income exclusion, but they are late in filing the tax return...

Americans living abroad have a hard time keeping U.S. bank accounts open.  As soon as the bank (or investment firm *cough* Merrill Lynch *cough*) finds...

Hello from Phil and welcome again to the Friday Edition. Every other Friday you get your dose of international tax news from me. If you...

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This is a tip for those of you who are overseas and will be filing a paper income tax return for 2015 with the IRS....

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