Choice of Entity for Foreign Businesses Owned by American Entrepreneurs: Common Corporate Structures American entrepreneurs abroad face brutally complex U.S. international tax rules that apply...
Indirect and Constructive Ownership Rules for Form 5471 Sometimes it is obvious when a U.S. taxpayer needs to file a Form 5471. However, indirect and...
The Nine Filing Categories of Form 5471 There were four categories of Form 5471 filers, then five. Now there are nine. This session is a...
Guide to Global Intangible Low-Taxed Income (Sec. 951A) U.S. shareholders of foreign corporations have a new pass-through income category to contend with: Global Intangible Low-Taxed...
Form 5471: New Schedules Q & R to report CFC Income and Distributions US Persons who own stock in Controlled Foreign Corporations (CFCs) might be...
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...
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