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July 2017 International Tax Lunch: Form 8621: Mark-to-Market and QEF Basics

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July 24, 2017 - Rachel Allen

July 2017 International Tax Lunch: Form 8621: Mark-to-Market and QEF Basics

Form 8621: Mark-to-Market and QEF Basics

Passive foreign investment companies (PFICs) have a notoriously punitive tax treatment. Fortunately, there are two different elections that may be made to reduce tax. Learn how the Mark-to-Market and QEF elections can provide a better tax result than the default treatment, when those elections may be used and how to perform the necessary calculations and prepare Form 8621.

Presenter: Debra Rudd

Materials: Dropbox

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July 10, 2017 - Rachel Allen

June 2017 International Tax Lunch: The Exit Tax

The Tax Consequences of Relinquishing U.S. Citizenship or Green Card Status

U.S. citizens and green card holders are taxable on worldwide income. Terminating citizenship or resident status means Uncle Sam can no longer collect tax from them. Predictably, there are tax hurdles to surmount before being free of the U.S. tax system. Receive an introduction to the exit tax rules: who is caught by them? What are the paperwork requirements? Who must pay tax for the privilege of exiting the U.S. tax system?

Presenter: Phil Hodgen

Materials: Dropbox

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May 26, 2017 - Rachel Allen

May 2017 International Tax Lunch: Foreign Corporation Investing in U.S. Real Estate Through a LLC

Foreign Corporation Investing in U.S. Real Estate Through a LLC

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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April 14, 2017 - Rachel Allen

April 2017 International Tax Lunch: Reporting PFICs with Insufficient Data

Reporting PFICs with Insufficient Data

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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March 13, 2017 - Rachel Allen

March 2017 International Tax Lunch: How to Report an Accumulation Distribution from a Foreign Nongrantor Trust

How to Report an Accumulation Distribution from a Foreign Nongrantor Trust

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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