I am going to throw a series of posts here that are aimed at U. S companies that are expanding their business operations overseas.
I’m talking to CEOs here. People who need to make decisions.
If your business operations have a border running through them, then your CFO and accountants have all talked to you about international tax. How on earth are you going to make sense of all this arcane gibberish you hear? Subpart F. Transfer pricing. You know they’re talking in English but how can you fit all of that conversation and advice into a decision model and move forward with your business decisions? And how do you know if you’ve made a sound decision.
You’re busy. You need to understand the big picture, make a decision, pass implementation along to someone you trust, and be able to know when they’re done with the job. All without incurring brain damage.
(There’s nothing worse than trying to force a CEO to become an instant international tax expert.)
This series will describe how I work my way through tax planning for cross-border business deals and business operations. I hope the methodology is useful for you, and helps you frame the problem and choose a course of action.
And I will never mention tax at all. What never? Well, hardly ever. OK. We’ll keep it to a minimum–just so you can understand what the High Priests of Tax are jabbering about. (And you can call BS on ’em, too).
Phil Hodgen
Philip D. W. Hodgen is the principal attorney of HodgenLaw PC, an international tax law firm based in Pasadena, California. He earned his undergraduate degree from Claremont McKenna College and his law degree from the School of Law at the University of California, Los Angeles. He then went on to earn a Master of Laws degree with a specialty in taxation from the University of San Diego School of Law. Admitted to the California bar in 1982, Phil spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991.
Phil is a past chair of the International Tax Committee of the State Bar of California's Tax Section and was a member of the Executive Committee of the State Bar of California's Tax Section for 2004-2007. Phil frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, and real estate professionals.
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Tax laws change over time, and the information in this post above may be less accurate today than it was at the time of the last revision. This post is not tax advice for your specific situation. Please contact an international tax professional to get personalized advice for your situation.
