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March 18, 2018 - Phil Hodgen

Upcoming Section 965 Workshop and a Collection of Links

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!

Rufus Rhoades will give a one-hour free workshop on March 23, 2018 at 9:00 am Pacific Time. Register here; it’s free.

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

American Business Abroad Minimultinationals PFIC and CFCs Speeches, Publications, and Events
November 14, 2016 - Phil Hodgen

NYSSCPA International Tax Conference, 26 January 2017 – I’m speaking about expatriation

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.

Sign up to attend in person or livestreamed on the web.

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

Speeches, Publications, and Events
November 11, 2016 - Phil Hodgen

Tax Planning and Compliance for Multinational Families – 02 Dec 2016

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.

Sign up on the CalCPA website.... continue reading

Speeches, Publications, and Events
October 6, 2016 - Phil Hodgen

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 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

Speeches, Publications, and Events
November 13, 2015 - Phil Hodgen

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 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

Expatriation Speeches, Publications, and Events