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September 2017 International Tax Lunch: Foreign Grantor Trusts

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September 21, 2017 - Rachel Allen

September 2017 International Tax Lunch: Foreign Grantor Trusts

Foreign Grantor Trusts: When to Use Them and How To Do the Tax Compliance

Trusts are great for transferring wealth from one generation to the next. But when that transfer is from a nonresident to a U.S. resident, there are a number of competing factors for how to make that transfer happen. This session talks about classic foreign parent/U.S. child estate planning for foreign assets, using foreign grantor trusts for income tax and estate tax efficiency. Also, cover the tax compliance required during the parents’ lifetimes and after they die.

Presenter: Phil Hodgen

Materials: Dropbox

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September 7, 2017 - Rachel Allen

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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July 24, 2017 - Rachel Allen

July 2017 International Tax Lunch: Form 8621: Mark-to-Market and QEF Basics

Form 8621: Mark-to-Market and QEF Basics

Passive foreign investment companies (PFICs) have a notoriously punitive tax treatment. Fortunately, there are two different elections that may be made to reduce tax. Learn how the Mark-to-Market and QEF elections can provide a better tax result than the default treatment, when those elections may be used and how to perform the necessary calculations and prepare Form 8621.

Presenter: Debra Rudd

Materials: Dropbox

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July 10, 2017 - Rachel Allen

June 2017 International Tax Lunch: The Exit Tax

The Tax Consequences of Relinquishing U.S. Citizenship or Green Card Status

U.S. citizens and green card holders are taxable on worldwide income. Terminating citizenship or resident status means Uncle Sam can no longer collect tax from them. Predictably, there are tax hurdles to surmount before being free of the U.S. tax system. Receive an introduction to the exit tax rules: who is caught by them? What are the paperwork requirements? Who must pay tax for the privilege of exiting the U.S. tax system?

Presenter: Phil Hodgen

Materials: Dropbox

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May 26, 2017 - Rachel Allen

May 2017 International Tax Lunch: Foreign Corporation Investing in U.S. Real Estate Through a LLC

Foreign Corporation Investing in U.S. Real Estate Through a LLC

A foreign corporation may wish to invest in U.S. real property. A common holding structure is to have the foreign corporation organize a U.S. limited liability company, then use the LLC to acquire the property without electing to treat the LLC as a corporation. Learn how the U.S. taxes the foreign corporation’s rental income and gains from the sale of the U.S. real estate.

Presenter: Haoshen Zhong

Materials: Dropbox

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