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March 2020 International Tax Lunch: Foreign Owners Of Domestic Corporations And Preparing Form 5472

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March 30, 2020 - Rachel Allen

March 2020 International Tax Lunch: Foreign Owners Of Domestic Corporations And Preparing Form 5472

Foreign Owners Of Domestic Corporations And Preparing Form 5472

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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February 25, 2020 - Phil Hodgen

February 2020 International Tax Lunch: Acquisition of U.S. Real Estate by Nonresidents

Acquisition of U.S. Real Estate by Nonresidents: Selecting the Holding Structure

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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February 6, 2020 - Phil Hodgen

January 2020 International Tax Lunch: Expatriation—The Tax Consequences Of Relinquishing US Citizenship

Expatriation—The Tax Consequences Of Relinquishing US Citizenship

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: Debra Rudd

Materials: Dropbox

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December 13, 2019 - Rachel Allen

December 2019 International Tax Lunch: Inbound Executives of Foreign Corporations

Inbound Executives of Foreign Corporations: Selected U.S. Income Tax Issues from the Individual’s Point of View

Tax planning gets complicated when you are working with a nonresident coming to the U.S. to work for a while. You need to plan for the transition from nonresident to resident (with different rules for income tax and estate/gift tax), a period of years while the individual is a U.S. resident, followed by an expected return to nonresident status.

Identifying the issues early helps you to minimize tax costs and U.S. tax compliance costs. This session will walk you through the questions that come up—and how to address them—when a foreign executive or other individual comes to the United States as a long-term but temporary resident.... continue reading

December 11, 2019 - Rachel Allen

November 2019 International Tax Lunch: Dual Status Returns

Dual Status Returns—What They Are, How They Work, How to Prepare Them

When someone becomes a U.S. person for tax purposes mid-year or ceases to be a U.S. person for tax purposes mid-year, they may be eligible to file a dual-status return. A dual-status return reports income for part of the year as a resident and part of the year as a nonresident. Learn how to identify the transition date; how income, exemptions, deductions and credits work on dual-status returns; how the foreign earned income exclusion can be applied; and how to prepare a dual-status return.

Presenter: William Shiraga

Materials: Dropbox

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