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 income recognition in the 2017 tax year, so there is not a lot of time to figure this one out!
I call this a workshop because the intention is for Rufus to talk a bit about the new law, then we will open it up for questions and input. Some of you out there are smart about Section 965, so please share with us.... continue reading
Just a heads-up (and shameless promotion) for this upcoming event.
I am giving a presentation at the New York State Society of Certified Public Accountants’ International Tax Conference on January 26, 2017.
The topic is expatriation.
And many thanks to the Committee (and especially Susan Brown Otto) for inviting me.
I will be in New York for a few extra days, in the name of fun, etc. My wife is coming with me on this trip. 🙂 She lived in Manhattan for 15 years before moving to California (where I met her) so she takes every opportunity she can to return to NYC.... continue reading
I just received the reviews from my October 26, 2016 all-day course for CalCPA, “Tax Planning and Compliance for Multinational Families.” This comment made me happy:
Easygoing, unpretentious and knows his stuff…
If you want to attend, I will be presenting the course live in San Francisco on December 2, 2016. This event will also be webcast live on December 2.
Eight hours of glorious CPE/MCLE credits. Get ‘em while they’re hot.
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 green card” program, provides a path to American citizenship for the well-to-do.
We are seeing the rise of a new type of person–the multinational individual. Tax professionals have long known how to deal with multinational business operations, but now we are confronted with the same high level of multi-country tax complexity, applied to people.... continue reading
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 hodgen.com/lists. This includes our fabulous new "CalCPA International Tax Conference and Other Events" list, which I will pimp heavily in about two seconds.
This email is coming to you from Houston, where I am going to give a talk on expatriation to the 18th Annual Texas International Tax Symposium.... continue reading