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Introduction All of the profits generated by a minimultinational enterprise will be exposed in real time to the U.S. tax system. Chapter 2 explains why....

American minimultinationals are small (for various definitions of "small") business enterprises subjected to the U.S. tax system. There are many ways that a minimultinational becomes...

What's an American Minimultinational? What do I mean by American minimultinational? Multinational A multinational business operates in multiple countries, exposed to multiple tax-hungry governments. Apple....

Nonresidents often show up and sign contracts to buy U.S. real estate in their own names. Then, before the sale is complete, they set up...

I received an email from Scott, a good friend who, well, does taxes in Mexico. He had a question about an American couple in Mexico...

Let’s look at the taxation of income earned by spouses living in community property jurisdictions. When a U.S. person is married to a nonresident alien,...

Hello from Singapore by way of Jakarta, and welcome to the Friday Edition. It's all alt-country1 and international tax here, folks. Go fire up Ribbon...

Proving the Obvious In a quick email exchange I had with Susan Brown Otto (hi Susan) we touched on a topic that deserves attention. The...

Yet Another "As If" And the preparation for next Friday's Section 962 workshop dragged my attention across a sleepy backwater of the Internal Code: Section 951A(f)(1)(A)....

Sometimes you need to confirm situation normal. This is one of those times. Thanks to correspondent BZ for triggering the discussion of this topic. Here...

Question From Section 965 Workshop We received a question from our March 23, 2018 workshop discussion about Section 965 about the interplay between the new...

Does a treaty election to be taxed as a nonresident of the United States trigger a Form 5472 filing requirement? The Schrödinger's cat meme gives...

Simple question: A taxpayer who wishes to invoke an income tax treaty to claim nonresident alien status for U.S. income tax purposes--must Form 8833 be...

Section 199A Deductions Reader B.B. from Miami Beach asked a such a simple1 question: Are NRAs with pass-through U.S. entities eligible for the [IRC Section...

Poker players are always looking for tells -- inadvertent signals by their opponents. The Tax Cuts and Jobs Act has a tell. Our Federal government...

There has been a lot of ballyhoo over the last few years about mega-multinationals (like Apple and Google) and their international tax structures. The amounts...

Self-employed people are enterprises engaged in commerce without using a business entity, like a corporation or limited liability company. Human-scale businesses can be large, and...

Congress Hates Foreign Trusts Congress hates foreign trusts.1 We know this because: Distributions to U.S. beneficiaries from some foreign trusts (foreign nongrantor trusts, to be...

How I Think About Real Estate Holding Structures Foreign investors in U.S. real estate always have the same question: How should I own the real...

The foreign earned income exclusion is a marvelous thing for Americans abroad. It eliminates income tax entirely on a fairly large chunk of income. Americans...