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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 choices available to an American entrepreneur abroad. 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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U.S. shareholders of foreign corporations must file Form 5471. But how do you know how much stock you own, and indeed if you are even an “owner”? The constructive ownership rules and attribution rules for Form 5471 are complicated, and getting this wrong might mean that you miss a filing requirement. Learn which rules to apply for different categories of Form 5471 filing requirements. Learn how to apply IRC §§318, 6038, and 6046 to find your answers.
Presenter: Phil Hodgen
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. income tax liability. Qualifying for these benefits, however, is complex and understanding what may be excluded is not always clear. Learn how to determine whether an individual will qualify for the exclusion and how to prepare Form 2555.
Presenter: Phil Hodgen
Materials: Dropbox
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Foreign owners of domestic corporations and foreign corporations engaged in a U.S. trade or business may have to file Form 5472. Complex attribution rules mean that identifying the reporting requirements can be a difficult task. Learn how to identify when a Form 5472 is required, what types of attribution rules may apply and some of the major issues that need to be reported on Form 5472.
Presenter: Phil Hodgen
Materials: Dropbox
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Foreign investors can own U.S. real estate using a variety of holding structures. There is no simple and obviously “best” choice. This session compares taxation of rental income and capital gain, as well as estate and gift tax exposure for a foreign investor. With the 2017 tax law changes, corporations are now much more interesting than they used to be.
Presenter: Phil Hodgen
Materials: Dropbox
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