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....
Recent Articles
Minimultinationals Chapter 02: It’s All Taxable to You
Phil Hodgen March 19, 2019
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....
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....
Upcoming Section 965 Workshop and a Collection of Links
Phil Hodgen March 18, 2018
The Tax Cuts and Jobs Act completely rewrote Section 965 to force a one-time repatriation of deferred earnings and profits in foreign corporations. It forces...
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