Introduction to Form 5472 Form 5472 filing requirements apply to foreign-owned domestic corporations and domestic disregarded entities, as well as foreign corporations engaged in a...
Covered Expatriates: The Exit Tax and Beyond Covered expatriates are subject to the exit tax. There are several different ways that the exit tax is...
Net Worth Test for Expatriation Expatriates have to navigate three tests to determine whether they will be covered expatriates. In this session, we will discuss...
Choosing a Holding Structure for Investment in U.S. Real Estate by Nonresidents Foreign investors can own U.S. real estate using a variety of holding structures....
Form 5471: The Indirect and Constructive Ownership Rules Sometimes it is obvious when a U.S. taxpayer needs to file a Form 5471. However, with the...
The Nine Filing Categories of Form 5471 There were four categories of Form 5471 filers, then five. Now . . . there are nine. This...
Guide to Global Intangible Low-Taxed Income (Section 951A) U.S. shareholders of foreign corporations have a new pass-through income category to contend with: Global Intangible Low-Taxed...
Section 962 Election Statement: Purpose and Requirements An individual who makes the Section 962 election must send a statement to the IRS with their return....
Foreign Owners of Domestic Corporations and Preparing Form 5472 Form 5472 filing requirements apply to foreign-owned domestic corporations and domestic disregarded entities, as well as...
Asset Taxation During and After Expatriation Covered expatriates are subject to the exit tax. There are several different ways that the exit tax is implemented....
Net Worth Test for Expatriation Expatriates have to navigate three tests to determine whether they will be covered expatriates. In this session, we will discuss...
International Tax Lunch: Partnership Investment in US Real Estate by Nonresidents How can you structure foreign investments in U.S. real estate when you have a...
International Tax Lunch: Choosing a Holding Structure for Investment in U.S. Real Estate Foreign investors can own U.S. real estate using a variety of holding...
International Tax Lunch: Solving Individual Problems with Tax Treaties Tax treaties between the United States and other countries cover a variety of topics, including income....
Section 962 - Should I be Taxed as Corporation? The new international tax rules now make most foreign corporation income immediately taxable to U.S. shareholders...
Choice of Entity for Foreign Businesses: Three Common Corporate Structures American entrepreneurs abroad face brutally complex U.S. international tax rules. These rules add complexity, tax...
Form 5471 - Categories & Attribution Rules U.S. shareholders of foreign corporations must file Form 5471. But how do you know how much stock you...
Foreign Earned Income Exclusion And How To Prepare Form 2555 The Foreign Earned Income Exclusion and related housing deduction/exclusion are a way for Americans abroad...
Foreign Owners Of Domestic Corporations And Preparing Form 5472 Foreign owners of domestic corporations and foreign corporations engaged in a U.S. trade or business may...
Acquisition of U.S. Real Estate by Nonresidents: Selecting the Holding Structure Foreign investors can own U.S. real estate using a variety of holding structures. There...
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