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The new international tax rules now make most foreign corporation income immediately taxable to U.S. shareholders (via the Subpart F and GILTI rules). Section 962 gives individual taxpayers an election to be taxed on Subpart F income and GILTI at corporate tax rates (21%) rather than individual tax rates (as high as 37%).
Should individual shareholders make this election? (Hint: the election’s consequences are not all rainbows and unicorns.)
Presenter: Phil Hodgen
Materials: Dropbox
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When a U.S. beneficiary receives a distribution from a foreign trust, the way the distribution is taxed depends on whether the trustee gives the beneficiary the right paperwork. This presentation looks at the all-too-common scenario where a trustee does not provide the necessary paperwork to prevent bad tax results. Learn how to calculate the accumulation distribution under the default rules, how to compute the tax to the beneficiary, and how to prepare the tax forms to report the distribution.
Presenter: Debra Rudd
Materials: Dropbox
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American entrepreneurs abroad face brutally complex U.S. international tax rules. These rules add complexity, tax liability, and expense to the entrepreneur’s life. This session will walk you through all of the major holding structures for an American entrepreneur abroad to operate a normal operating business. We will explore the expected U.S. tax cost as well as the paperwork load for each structure.
Presenter: Phil Hodgen
Materials: Dropbox
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Many nonresidents hold U.S. real estate through a foreign corporation. In this overview level presentation, learn the withholding requirements, what tax forms to file, and when to file them for each stage of real estate ownership—purchase, rental, disposition—through a foreign corporation.
Presenter: William Shiraga
Materials: Dropbox
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The Foreign Earned Income Exclusion and related housing deduction/exclusion are a way for Americans abroad to reduce or eliminate their U.S. tax liabilities. But qualifying is complex and understanding exclusions is often unclear. Learn what exclusions are permitted and preparation of Form 2555.
Presenter: Phil Hodgen
Materials: Dropbox
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