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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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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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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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What do you do when you need to report a PFIC but lack the necessary information to do so? This is a common scenario for PFICs held in foreign tax-deferred accounts that are not deferred in the US, or when a taxpayer has held a PFIC for many years and no longer has all of the records. This presentation will discuss what data is needed when completing Form 8621, what issues may arise as a result of not having complete data, and strategies for preparing Form 8621 with partial data.
Presenter: Debra Rudd
Materials: Dropbox
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In this month’s International Tax Lunch, Phil will walk you through the preparation of an income tax return for a U.S. beneficiary of a foreign nongrantor trust. You will learn how how to identify a trust distribution, then how to prepare Form 3520 and Form 4970, and where the numbers go on the beneficiary’s Form 1040.
Presenter: Phil Hodgen
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