Blog   /   Foreign Business Activities in the USA

December 25, 2015 - Phil Hodgen

Latest developments (and Killspencer)

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 tax goodness. You signed up for this newsletter, but if you want to stop getting it, no problem — just click the Unsubscribe link at the bottom of the email.

Next International Tax Lunch

January 8, 2016 — our regular monthly International Tax Lunch series returns after the Christmas break. Noon, Pacific time. In person or dial in.

I will be doing one hour on the foreign earned income exclusion and how to prepare Form 2555.... continue reading

American Business Abroad Foreign Business Activities in the USA Friday Edition
December 18, 2013 - Phil Hodgen

Presentation and Q&A: Global Real Estate Transactions

What: Global Real Estate Transactions — Presentation followed by Q&A
Time: Tuesday, January 14, 2014 from 1:00 PM to 2:00 PM
Where: Malibu Public Library — 23519 Civic Center Way, Malibu, CA  90265
Host: Malibu Association of Realtors – Global Committee

Phil will be part of a presentation and Q&A session along with Mitch Creekmore, SVP with the Stewart Title Guaranty Company.

If you are interested in joining the event, please contact Olivia at olivia.park (at) continue reading

Foreign Business Activities in the USA Speeches, Publications, and Events US Real Estate Investments
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
March 16, 2011 - Phil Hodgen

East West Bank comments on IRS requirement for nonresident interest reporting

The IRS wants all U.S. banks to report the amount of interest earned on bank deposits owned by nonresident aliens.

This last came up 10 years ago, and was resoundingly shot down for obvious reasons. Leadership at the IRS has revived the idea. Cue the obligatory George Santayana reference.

Today I saw in Tax Notes Today a letter from Douglas Krause, General Counsel for East West Bank. They happen to be headquartered right here in my hometown of Pasadena, California.

Mr. Krause succinctly identifies what’s wrong with the idea. I’m a total fanboi.

CC:PA:LPD:PR (REG-146097-09), Room 5203,
Internal Revenue Service
PO Box 7604
Ben Franklin Station,
Washington, DC 20044

February 22, 2011

RE: IRS REG-146097-09

Dear Sir/Madam:

California based East West Bank is the largest bank in the nation targeted at serving the Asian American communities throughout the United States of America.

... continue reading
Foreign Business Activities in the USA
September 2, 2010 - Phil Hodgen

Estate tax sunset in 2010 applies to nonresidents

I received an email inquiry from a CPA friend about this, so I thought I would share it generally.


Does the 2010 repeal of the estate tax apply to nonresidents of the United States?


Yes.  The repeal applies to residents and nonresidents alike.


The estate tax disappeared on December 31, 2009.  It is designed to re-appear on January 1, 2011.  Tag that:  #politicalgames

The Tax Geek’s explanation

Section 2210(a) of the Internal Revenue Code says:

“Except as provided in subsection (b), this chapter shall not apply to estates of decedents dying after December 31, 2009.”

“This chapter” means Internal Revenue Code, Subtitle B, Chapter 11, which contains Sections 2001 through 2210.  ... continue reading

Foreign Business Activities in the USA Nonresidents with US Activities