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February 2017 International Tax Lunch

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February 10, 2017 - Rachel Allen

February 2017 International Tax Lunch

Using Foreign Corporations to Defer US Tax on your Foreign Consulting Income

Suppose you are a US citizen and the owner of a popular consulting business.  You have clients all over the world.  You provide consultations for a fee, and you sell recordings of your seminars and publications.  Is there any way you can leverage a foreign corporation to defer US tax on the income, so you have more resources to expand?  What are the costs of deferral?

Who: Haoshen Zhong
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January 16, 2017 - Rachel Allen

January 2017 International Tax Lunch

Foreign Mutual Funds and Form 8621 — the Default Rules in Depth

In this month’s tax lunch presentation, we will work through a real world scenario where a US person buys into a foreign mutual fund — which happens to be a PFIC — held in a foreign investment account. Over several years, he receives dividends (some of which are reinvested), some of his shares are redeemed to pay account fees, and finally, he sells all his shares in the PFIC.

We will cover the real calculations in detail, including running basis as the share holdings change over time, excess distributions, tax, and interest.... continue reading

December 12, 2016 - Rachel Allen

December 2016 International Tax Lunch

Estate Taxation and Expatriation

Presenter: Phil Hodgen

Everyone focuses on the income tax consequences of renouncing U.S. citizenship or giving up a green card. Am I a covered expatriate? Will I have to pay an exit tax?

Income tax and covered expatriate status is only part of the problem.

Many expatriates – covered or not – will continue to own U.S. assets after renouncing citizenship or abandoning their green cards. Real estate. U.S. stock, bonds, and mutual funds. Retirement accounts. These assets can create a U.S. estate tax problem.

If you will own U.S. assets after you expatriate, listen in as Phil describes the tax rules, your exposure to estate tax risk, and what you can do about these risks – both before and after expatriation.... continue reading

November 14, 2016 - Rachel Allen

November 2016 International Tax Lunch

Selling Goods Across the US Border

Presenter: Haoshen Zhong

Suppose you are a foreign manufacturer or exporter, and you want to sell your goods in the US. What federal tax considerations are there? Suppose you are a US manufacturer or exporter, and you want to sell your goods outside the US. What tax planning can you do?

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November 14, 2016 - Rachel Allen

October 2016 International Tax Lunch

The Portfolio Interest Exception: All Secrets Revealed

Presenter: Phil Hodgen

Foreign lenders can make mortgage loans on U.S. real estate and collect the interest tax-free.  This month, Phil talks about the portfolio interest exception.  Why does it work?  How does it work?  Phil will demystify the magic language that must be included in the loan documents, and emphasize practical tips to follow when you are setting up such a loan.  A sample promissory note template is included with the slides.

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