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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...

Expatriation—The Tax Consequences Of Relinquishing US Citizenship U.S. citizens and green card holders are taxable on worldwide income. Terminating citizenship or resident status means Uncle...

Inbound Executives of Foreign Corporations: Selected U.S. Income Tax Issues from the Individual's Point of View Tax planning gets complicated when you are working with...

Dual Status Returns—What They Are, How They Work, How to Prepare Them When someone becomes a U.S. person for tax purposes mid-year or ceases to...

Foreign Corporation Information Reporting—Form 5471 and Attribution Rules When a U.S. person owns interest in a foreign corporation or has some other relation with a...

How To Report An Accumulation Distribution From A Foreign Nongrantor Trust When a U.S. beneficiary receives a distribution from a foreign trust, the way the...

Reporting Requirements For A Foreign Corporation Holding A U.S. Rental Property Many nonresidents hold U.S. real estate through a foreign corporation. In this overview level...

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...