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Category: Minimultinationals

"Own" is Such a Difficult Word

Phil Hodgen April 28, 2023

Form 5471 is hard because, among other reasons, you have to figure out the meaning of the word "own." There's your understanding of the word....

Subpart F Income: An Overview

Phil Hodgen March 17, 2023

Introduction We have default assumptions about everything. "Unless proven otherwise, X is true." For U.S. taxpayers who own stock of controlled foreign corporations, the default...

Why Form 5471 Exists

Phil Hodgen February 17, 2023

Form 5471 exists because Subpart F (IRC §§951-965) exists. Or to be more precise, Form 5471 exists because Subpart F exists and taxpayers are smarter...

Why a Section 962 Statement is Necessary

Phil Hodgen April 21, 2020

On July 10, 2020 I will  present a live Section 962 webcast that goes into excruciatingly painful detail about preparing a Section 962 tax return....

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....