Resources / International Tax Lunches

International Tax Lunches

August 2016 International Tax Lunch: Taking Your Trust Across the US Tax Border
July 2016 International Tax Lunch: How To Use Nongrantor Trust Structures For Foreign Investment In U.S. Real Estate
May 2016 International Tax Lunch: PFIC Tests in Depth for Operating Companies
April 2016 International Tax Lunch: Tax Planning for Foreign Service Providers with U.S. Clients
October 2016 International Tax Lunch: The Portfolio Interest Exception: All Secrets Revealed
November 2016 International Tax Lunch: Selling Goods Across the US Border
December 2016 International Tax Lunch: Estate Taxation and Expatriation
January 2017 International Tax Lunch: Foreign Mutual Funds and Form 8621 — the Default Rules in Depth
February 2017 International Tax Lunch: Using Foreign Corporations to Defer US Tax on your Foreign Consulting Income
March 2017 International Tax Lunch: How to Report an Accumulation Distribution from a Foreign Nongrantor Trust
April 2017 International Tax Lunch: Reporting PFICs with Insufficient Data
May 2017 International Tax Lunch: Foreign Corporation Investing in U.S. Real Estate Through a LLC
July 2017 International Tax Lunch: Form 8621: Mark-to-Market and QEF Basics
August 2017 International Tax Lunch: Claiming Foreign Tax Credit with a Hybrid Entity
September 2017 International Tax Lunch: Foreign Grantor Trusts
October 2017 International Tax Lunch: Dual Status Returns
November 2017 International Tax Lunch: PFIC Tests In-Depth for Operating Companies
December 2017 International Tax Lunch: Irrevocable Trusts for Real Estate
January 2018 International Tax Lunch: Form 5472 Filing Requirements and Preparation
February 2018 International Tax Lunch: Pensions as Foreign Trusts
March 2018 International Tax Lunch: Treaty Election for Nonresident Status
April 2018 International Tax Lunch: How Foreign Mutual Funds are Taxed and Reported
May 2018 International Tax Lunch: Withholding on Foreign Members of LLCs and Partnerships
June 2018 International Tax Lunch: Taxation of Community Property for Americans Abroad (Section 879)
July 2018 International Tax Lunch: An In-depth Guide to the Certification Test
August 2018 International Tax Lunch: Form 5471 Categories and Attribution Rules
September 2018 International Tax Lunch: Dual-Status Returns
October 2018 International Tax Lunch: The Exit Tax
November 2018 International Tax Lunch: FIRPTA Withholding
December 2018 International Tax Lunch: PFIC to CFC
January 2019 International Tax Lunch: Tax Treaties for Regular People
February 2019 International Tax Lunch: Foreign Ownership of US Property for Personal Use
March 2019 International Tax Lunch: Form 5472 Filing Requirements and Preparation
April 2019 International Tax Lunch: Foreign Earned Income Exclusion and How to Prepare Form 2555
May 2019 International Tax Lunch: Reporting Requirements For A Foreign Corp Holding US Rental Property
July 2019 International Tax Lunch: Accumulation Distribution From A Foreign Nongrantor Trust
September 2019 International Tax Lunch: Guide to Global Intangible Low-Taxed Income
October 2019 International Tax Lunch: Foreign Corporation Information Reporting—Form 5471 and Attribution Rules
November 2019 International Tax Lunch: Dual Status Returns
December 2019 International Tax Lunch: Inbound Executives of Foreign Corporations
January 2020 International Tax Lunch: Expatriation—The Tax Consequences Of Relinquishing US Citizenship
February 2020 International Tax Lunch: Acquisition of U.S. Real Estate by Nonresidents
March 2020 International Tax Lunch: Foreign Owners Of Domestic Corporations And Preparing Form 5472
April 2020 International Tax Lunch: Foreign Earned Income Exclusion
May 2020 International Tax Lunch: Form 5471 – Categories & Attribution Rules
June 2020 International Tax Lunch: Choice of Entity for Foreign Businesses
August 2020 International Tax Lunch: Guide to Global Intangible Low-Taxed Income
September 2020 International Tax Lunch: Section 962 – Should I be Taxed as Corporation?

August 2017 International Tax Lunch: Claiming Foreign Tax Credit with a Hybrid Entity

Claiming Foreign Tax Credit with a Hybrid Entity

The U.S. and foreign countries do not require consistent treatment of business entities: there can be an entity whose income is passed to the owners in a foreign country and is taxed to the entity in the U.S. These types of hybrid entities provide tax planning opportunities for the business owners.

Presenter: Haoshen Zhong

Materials: Dropbox

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