Section 965 and a new offer in compromise policy

In late 2017 our Trusted Servants(TM) in Congress blessed us with a new tax law. Among other features, the new law contained a spectacular Come to Jesus that absolutely hammered our minimultinational clients. I speak, of course, of Section 965. Section 965 Consider a foreign corporation owned by an American living abroad. The foreign corporation…

Dadon v. United States (2020)

Dadon v. United States: Full Case I have posted the full text of the case Dadon V. United States to make it easy to cross-reference to my previous blog post discussing what happened here.  Don’t treat this version of the opinion as absolute Gospel. I might have messed something up converting the file for posting….

Everyone Has a Plan ‘Til They Get Punched in the Mouth

Welcome to The Friday Edition, the biweekly newsletter on international tax things, because, well, that’s what I do in my day job. This episode is for people who are aware that they have a tax problem. You might be running a business and know that there are a lot of unfiled forms (Form 5471 is…

Hear Atossa Abrahamian Speak About Buying and Selling Citizenship

There is a booming trade in selling citizenship and permanent resident status as a path to citizenship. People think that only small countries do this. While small countries do sell passports (St. Kitts is a prominent example), large countries do this as well. Even the United States, under the guise of the EB-5 “buy a…

From RUH, Terminal 1

Greetings from the Premier Lounge in Riyadh’s King Khaled International Airport, Terminal 1. I’ve been up since 4:20 a.m. because inexplicably someone at the hotel decided to program a wake-up alarm into that little glowing box beside the bed. It is now closing in on midnight and we take off shortly before 1 a.m. I…

Wherein I pimp the CalCPA International Tax Conference and tell covered expatriates something depressing

Hey it's Phil and this is the biweekly Friday Edition. You signed up to get it, but if your inbox is suffering, just click the "unsubscribe" link at the bottom of this email and it will stop coming. On the other hand we have other fabulous email newsletters that you can subscribe to, at….

Who files Form 8854 and what if you’re late?

Hello again from Phil Hodgen. You signed up for my biweekly Expatriation Only newsletter. If you want to stop getting it, just click the Unsubscribe link at the bottom of the email. We have other email lists, and you can sign up for them at New email list–please sign up We started up a…

New Mailing List – CalCPA International Tax Events

There is a new mailing list on our page, started today:  the CalCPA International Tax Events list. The purpose of the list is to increase the number of people who attend the CalCPA International Tax Conference. I am the chair of that conference. We had a great event yesterday in San Francisco — our…

International Tax Lunch: Form 3520 and 3520-A for Foreign Pensions and Trusts

Who: Haoshen Zhong, Attorney

What: The IRS expects U.S. citizens and residents to report their transactions and relationships to foreign trusts on Form 3520. They are required to report ownership in foreign trusts on Form 3520-A. Most foreign pension plans are treated like foreign trusts and are subject to the same reporting and tax requirements. This session discusses briefly how foreign trusts are taxed and reported, using an example of a U.S. citizen employed abroad with a pension plan.

When: Friday, March 13 at 12:00PM Pacific Time

Where: HodgenLaw PC

International Tax Lunch Session: Form 3520 and Foreign Trust Distributions to U.S. Beneficiaries

What: Form 3520 and Foreign Trust Distributions to U.S. Beneficiaries When: Friday, June 13, 2014 at Noon (Pacific Time)
 Where: HodgenLaw, 80 S. Lake Avenue, Suite 680, Pasadena, CA 91101
 Who: Phil Hodgen This month’s International Tax Lunch will be about Form 3520 and foreign trusts. When you are preparing an income tax return for a U.S. taxpayer…

International Tax Planning Comes Third

Tax planning across borders is complicated.  A massive public company has the budget to deal with complex international tax problems.  Privately-held businesses must deal with the same tax rules that Apple, Google, and Ford face.  But they don’t have the budget to deal with the legal and accounting costs that those highly complex rules will…

Associate Tax Lawyer

We solve international tax problems for people. That means looking eye-to-eye at someone, saying “I can help you” and delivering on that promise.  We need another lawyer to work with our team.  Success in this position means: When you’re given a task because the problem has already been figured out, you get the task done….

Email to a law student interested in international tax

I received an email from a third-year law student interested in international tax. I’m in Dubai and coming home next week to a mountain of work and intend to (1) be with my family; (2) be in the office working; and (3) run laps around the Rose Bowl. Nothing else until my vacation at the…