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November 10, 2015 - Phil Hodgen

Who files Form 8854 and what if you’re late?

Hello again from Phil Hodgen. You signed up for my biweekly Expatriation Only newsletter. If you want to stop getting it, just click the Unsubscribe link at the bottom of the email. We have other email lists, and you can sign up for them at

New email list–please sign up

We started up a new email list this weekend. It is called the CalCPA International Tax Events list. You should sign up.

This list is a thinly-disguised way to get you to attend the 2016 CalCPA International Tax Conference in November, 2016 in San Francisco, and to promote other CalCPA international tax events.... continue reading

Expatriation Speeches, Publications, and Events
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

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
May 18, 2015 - Phil Hodgen

International Tax Lunch: Using C corporations for nonresident investment in US real estate

Using C corporations for nonresident investment in US real estate

Come join us at our office in Pasadena as Philip Hodgen presents this month’s tax lunch. Feel free to stay after the presentation and ask questions regarding the topic, and to meet our team members as well.

Lunch and good company will be provided!

Who: Philip Hodgen, Attorney

What: Nonresidents frequently use corporations to hold U.S. real estate investments. Corporations are simple, understood by everyone, and easy to control. There are tax pitfalls, however. This month’s International Tax Lunch will highlight the things you need to think about when using corporations (U.S.... continue reading

Speeches, Publications, and Events
April 14, 2015 - Phil Hodgen

Agenda for Webinar for Noncovered Expatriates

Phil is presenting a webinar for noncovered expatriates on 24 April 2015. Here is what he will be covering.
Expatriation Speeches, Publications, and Events
March 16, 2015 - Phil Hodgen

Webinar for Noncovered Expatriates

Course Overview:
Part 1. Introduction/Overview
Part 2. The Certification Test
A. Overview - Certification Test
The only test that matters to you (net worth and net tax liability are not a problem by definition)
B. How you become a covered expatriate
The law, Form 8854 - what is required?
The Code and the question on Form 8854.
The hard questions - small errors, big errors, etc. - what are the risks?
C. How to prevent covered expatriate status

Which years matter?
What to look for in those years?
What to leave alone
What to fix
How to fix it
When to fix it
No Social Security Number?

Part 4. Dual Status Tax Returns
A. Basic requirement to file

Filing requirement for year of termination of resident/citizen status.
What about low income people otherwise exempt from filing?
Should you file a dual status tax return or a full-year resident status return?
B. What happens if you don't file, or you're late
C. Technical details
How to allocate income to before/after expatriation date
Paperwork for the citizen/resident portion of the year (Form 1040 as a statement)
How to flow numbers from your Form 1040 Statement to the Form 1040NR
Paperwork for the portion of the year after expatriation
Tax computation for the noncitizen/nonresident portion of the year
Treaties for the nonresident/noncitizen portion of the year
Other stuff - personal exemptions, standard deductions, dependents, etc.
Part 5. Retirement Plans After Expatriation
A. How are the distributions taxed
Default rules
Treaty rules
B. Using treaties to reduce U.S. tax
How it works
The paperwork
C. Withholding at source
How it works
Form W-8BEN
Form 1040NR
Part 6. Life After Expatriation
A. Social Security, Medicare
How it is taxed
Medical treatment paid for by Uncle Sam
B. U.S. real estate
Income taxation of rent
Estate taxation
Capital gains tax on sale
C. Estate planning for U.S. assets
Real estate
Stock market investments
D. Travel to the U.S.
Friday April 24, 2015
8:00AM to 10:00AM Pacific Time
Expatriation Speeches, Publications, and Events