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A foreign corporation may wish to invest in U.S. real property. A common holding structure is to have the foreign corporation organize a U.S. limited liability company, then use the LLC to acquire the property without electing to treat the LLC as a corporation. Learn how the U.S. taxes the foreign corporation’s rental income and gains from the sale of the U.S. real estate.
Presenter: Haoshen Zhong
Materials: Dropbox
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What do you do when you need to report a PFIC but lack the necessary information to do so? This is a common scenario for PFICs held in foreign tax-deferred accounts that are not deferred in the US, or when a taxpayer has held a PFIC for many years and no longer has all of the records. This presentation will discuss what data is needed when completing Form 8621, what issues may arise as a result of not having complete data, and strategies for preparing Form 8621 with partial data.
Presenter: Debra Rudd
Materials: Dropbox
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In this month’s International Tax Lunch, Phil will walk you through the preparation of an income tax return for a U.S. beneficiary of a foreign nongrantor trust. You will learn how how to identify a trust distribution, then how to prepare Form 3520 and Form 4970, and where the numbers go on the beneficiary’s Form 1040.
Presenter: Phil Hodgen
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Suppose you are a US citizen and the owner of a popular consulting business. You have clients all over the world. You provide consultations for a fee, and you sell recordings of your seminars and publications. Is there any way you can leverage a foreign corporation to defer US tax on the income, so you have more resources to expand? What are the costs of deferral?
Who: Haoshen Zhong
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In this month’s tax lunch presentation, we will work through a real world scenario where a US person buys into a foreign mutual fund — which happens to be a PFIC — held in a foreign investment account. Over several years, he receives dividends (some of which are reinvested), some of his shares are redeemed to pay account fees, and finally, he sells all his shares in the PFIC.
We will cover the real calculations in detail, including running basis as the share holdings change over time, excess distributions, tax, and interest.... continue reading
