Recent Articles
November 2022 International Tax Lunch: Choice of Entity for Foreign Businesses Owned by American Entrepreneurs
Rachel Allen December 21, 2022
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...
September 2022 International Tax Lunch: Indirect and Constructive Ownership Rules for Form 5471
Rachel Allen September 30, 2022
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...
August 2022 International Tax Lunch: The Nine Filing Categories of Form 5471
Rachel Allen September 02, 2022
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...
July 2022 International Tax Lunch: Guide to Global Intangible Low-Taxed Income (Sec. 951A)
Rachel Allen September 02, 2022
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...
June 2022 International Tax Lunch: Form 5471: New Schedules Q & R
Rachel Allen July 12, 2022
Form 5471: New Schedules Q & R to report CFC Income and Distributions US Persons who own stock in Controlled Foreign Corporations (CFCs) might be...
March 2022 International Tax Lunch: Introduction to Form 5472
Rachel Allen April 05, 2022
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...
February 2022 International Tax Lunch: Covered Expatriates - The Exit Tax and Beyond
Rachel Allen February 24, 2022
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...
January 2022 International Tax Lunch: Net Worth Test for Expatriation
Rachel Allen February 09, 2022
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...
October 2021 International Tax Lunch: Choosing a Holding Structure for Investment in U.S. Real Estate by Nonresidents
Rachel Allen November 10, 2021
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....
September 2021 International Tax Lunch: Form 5471: The Indirect and Constructive Ownership Rules
Rachel Allen September 28, 2021
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...
August 2021 International Tax Lunch: The Nine Filing Categories of Form 5471
Rachel Allen September 01, 2021
The Nine Filing Categories of Form 5471 There were four categories of Form 5471 filers, then five. Now . . . there are nine. This...
July 2021 International Tax Lunch: Guide to Global Intangible Low-Taxed Income (Section 951A)
Rachel Allen August 05, 2021
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...
June 2021 International Tax Lunch: Section 962 Election Statement - Purpose and Requirements
Rachel Allen July 07, 2021
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....
March 2021 International Tax Lunch: Foreign Owners of Domestic Corporations and Preparing Form 5472
Rachel Allen March 18, 2021
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...
February 2021 International Tax Lunch: Asset Taxation During and After Expatriation
Rachel Allen February 15, 2021
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....
January 2021 International Tax Lunch: Net Worth Test for Expatriation
Phil Hodgen January 21, 2021
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...
December 2020 International Tax Lunch: Partnership Investment in US Real Estate by Nonresidents
Rachel Allen December 16, 2020
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...
November 2020 International Tax Lunch: Choosing a Holding Structure for Investment in U.S. Real Estate
Rachel Allen November 19, 2020
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...
October 2020 International Tax Lunch: Solving Individual Problems with Tax Treaties
Rachel Allen November 03, 2020
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....
September 2020 International Tax Lunch: Section 962 - Should I be Taxed as Corporation?
Rachel Allen September 14, 2020
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...