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Category: Friday Edition

Minimultinationals Chapter 01: Overview of the Series

Phil Hodgen February 01, 2019

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...

American Minimultinationals: An Introduction

Phil Hodgen January 18, 2019

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....

June 15 Payment Dates for Section 965

Phil Hodgen April 13, 2018

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...

Section 965 and Net Investment Income Tax

Phil Hodgen March 30, 2018

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...

Section 199A Works for Nonresident Aliens

Phil Hodgen February 16, 2018

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...

Foreign Trust Distributions and How They're Taxed

Phil Hodgen November 13, 2017

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 Should I Own My U.S. Real Estate?

Phil Hodgen October 13, 2017

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...