In response to the tax law changes enacted December of 2017, we converted our PFICs Only newsletter to cover more topics that arise when a business crosses the US border–when a US person owns part of a foreign business or when a foreign person starts a business in the US. This is the first blog post under the new subject.
If you were paying attention to the tax law rewrite last year, you may have heard the term “global intangible low-taxed income” (GILTI). It is supposed to establish a minimum tax on foreign source income for multinational corporations.... continue reading
If you are an American living abroad and sweating the October 15 tax filing deadline for your 2016 income tax returns, there is a possible piece of relief. You may be able to qualify for a further extension of time for filing your tax return — to December 15, 2017.Summary
For American taxpayers living abroad, if you want to get a filing deadline of December 15, 2017 for your 2016 Form 1040, do this:
Here are the answers in a hurry:
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 home country when they sell assets or take pension distributions.
The double taxation problem has been largely solved for expatriates who live in Canada, but not (as far as I know) for other residents of countries.What’s a Double Taxation Problem?
Let’s talk first about what a double-taxation problem is. It occurs because two countries want to tax you, and neither country cares that the other country taxed you.
If you are a taxpayer in two different countries, both countries will impose their domestic tax laws on you, and insist on the right to force you to pay tax on your income.... continue reading
Today’s topic is based on some war stories we have seen. Here is the general situation we have had to deal with:
I am a US citizen living abroad and married to a foreign national. She and I both owned some PFICs. We transferred them to a family trust whose trustee is a private company we own 50-50. Our children and we are beneficiaries of the family trust. Do I have to report the PFICs held in the family trust as my own?
Today’s post will discuss some of the uncertainties and possible results for PFIC attribution through a trust.