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January 28, 2016 - Debra Rudd

Is a late MTM election under the inbound immigrant rules possible?

Hello from Debra Rudd.

You are receiving this email because you are signed up for our bi-weekly “PFICs Only” newsletter, delivered to your electronic mailbox every other Thursday at 6:00am Pacific time. To stop receiving this newsletter, scroll to the bottom of this email and click “unsubscribe”. On the other hand, if you would like to see the other newsletters that we offer, go to hodgen.com/newsletters.

Is a late MTM election under the inbound immigrant rules possible?

This week’s topic comes from a question I received a while ago from an anonymous reader:

Does an immigrant to the US get to apply the basis step up/transition rule if they did not do a MTM election in their first year of US residence?

... continue reading
Nonresidents with US Activities PFIC and CFCs
January 14, 2016 - Debra Rudd

PFIC held by a domestic partnership stops being a PFIC

Hey from Debra Rudd.

You are receiving this message because you are signed up for our “PFICs Only” mailing list, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. If you would like to stop receiving this newsletter, just scroll to the bottom of this email and click “unsubscribe”. To see what other newsletters we offer, go to hodgen.com/newsletters.

Work here

We are hiring.

You can see the job listings at hodgen.com/jobs. One admin/office manager, one accountant. We will also be posting a listing for an attorney soon.

For the accountant position, you might be straight out of school or you might have done your tour through the Big 4 or somewhere else and are disillusioned.... continue reading

PFIC and CFCs
January 8, 2016 - Phil Hodgen

Foreign life insurance and Americans abroad

Hello again from Phil Hodgen, and Happy 2016.

Work here

We are hiring.

You can see the job listings at hodgen.com/jobs. One admin/office manager, one accountant. That’s what’s on the plate at the moment.

But there will be more job listings to come in the next few months.

International Tax Lunch – Today

You are getting this at 6:00 a.m. Pacific time. At noon (Pacific time) today, our International Tax Lunch series for 2016 will kick off. I will be talking about the foreign earned income exclusion and Form 2555. Quick. Go to hodgen.com/lists and sign up so you can get the last-minute email with the conference call dial-in information.... continue reading

Americans Living Abroad Friday Edition PFIC and CFCs
December 17, 2015 - Debra Rudd

Taxation of distributions from PFICs in multi-tiered structures

Hi from Debra Rudd.

You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom of this message and click “unsubscribe”. To see what other newsletters we offer, go to hodgen.com/lists.

Taxation of distributions from PFICs in multi-tiered structures

For this week’s newsletter I will discuss the following scenario:

You, a US citizen, and your friend, a non-US person, form a foreign corporation in 2005. You each own 50% of it. Let’s call your corporation Investment Corp.

... continue reading
PFIC and CFCs
November 5, 2015 - Debra Rudd

Upcoming presentations and purging elections

Hello from Debra Rudd.

You are receiving this email because you are signed up for our “PFICs Only” newsletter, delivered directly to your electronic mailbox every other Thursday at 6:00 am Pacific time. To stop receiving this message, scroll down to the bottom and click “unsubscribe”. If you are interested in receiving more of these types of communications, check out our other mailing lists at hodgen.com/lists.

CalCPA International Tax Conference — November 6

Tomorrow, November 6, I will be speaking at the CalCPA International Tax Conference, a full-day event dedicated to practitioners who work with individuals whose tax situations cross the US border — either US persons living and working abroad, or foreigners coming to the US to work or make investments.... continue reading

PFIC and CFCs Speeches, Publications, and Events