HodgenLaw: International Tax
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Hi, I’m Phil Hodgen. I built our firm (back in 1988) so that real people could get their very tough IRS problems solved. I’ve hand-selected a team of accountants, attorneys, and other professionals to help you with your tax problems. I write about the toughest parts of tax law in my newsletter.
From Our Newsletter
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IRC §951A Exists to Solve a Problem Created by IRC §245A
Today, Let’s ask a “Why?” question and make sense of why IRC §951A exists. TCJA’s impact: a myriad of details and confusion IRC §951A arrived in late 2017 and caught everyone’s attention. A new tax! Everything in CFC-land became vastly more complicated. The Tax Cuts and Jobs Act promised a new, modern, efficient “territorial” tax…
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Subpart F Income in a Multi-Level Structure, Episode 3
This is Episode 3 of a series where we track $1,000 of subpart F income by a lower-tier CFC subsidiary, with cash distributions all the way up the stack to the U.S. shareholder–and see what happens. Catching up on this series In our previous two episodes, we traced $1,000 of dividend income (aka subpart F…
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Subpart F Income in a Multi-Level Structure, Episode 2
What happens when a subsidiary CFC pays a dividend to its parent CFC? Does that create subpart F income for the U.S. shareholder of the parent CFC? I am tracing $1,000 of generic dividend income received (from Nestlé) by Foreign Subsidiary as it is distributed upstream to eventually land in U.S. Citizen’s pocket. The end…