February 2019 International Tax Lunch: Foreign Ownership of US Property for Personal Use

February 2019 International Tax Lunch: Foreign Ownership of US Property for Personal Use

Foreign Ownership of US Property for Personal Use

Foreigners buy U.S. houses for personal use.  But how should they own those properties?  In this session, Phil Hodgen explains the estate tax and capital gain tax performance of eight different methods of holding title, from direct ownership to irrevocable trusts.

Presenter: Philip Hodgen

Materials: Dropbox

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January 2019 International Tax Lunch: Tax Treaties for Regular People

Using Income Tax Treaties—A Guide for Regular People and their Accountant

Everyone “knows” that tax treaties can be used to solve tax problems. But how, exactly, do you figure out whether a tax treaty is useful in your case? Receive guidance on using income tax treaties and more in this course.

Attendees will consider how do you prepare Form 8833 to claim the treaty benefits. Plus, determine the impact of claiming treaty benefits on the tax return paperwork and identify whether your income tax is a liability.

Presenter: Phil Hodgen

Materials: Dropbox

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December 2018 International Tax Lunch: PFIC to CFC

PFIC to CFC—Understanding Filing Requirements and Overlap

In this presentation, trace the evolution of the U.S. owners’ filing requirements with respect to a foreign startup company over the years as more U.S. owners buy in and the total U.S. ownership increases.

Examine the Form 8621 and Form 5471 filing requirements for each year for each of the US individuals involved. Cover how to make a purging election to tax the startup as a CFC (and not a PFIC) in the final year. Finally, briefly discuss the option of making a QEF election for the pre-CFC years.

Presenter: Deba Rudd

Materials: Dropbox

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November 2018 International Tax Lunch: FIRPTA Withholding

Withholding When a Foreign Person Sells U.S. Real Property

The Foreign Investment in Real Property Tax Act (FIRPTA) requires tax withholding when a foreign person transfers real property interest in the U.S. Learn what the withholding requirements are and how to meet them.

Presenter: Debra Rudd

Materials: Dropbox

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October 2018 International Tax Lunch: The Exit Tax

Expatriation: 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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