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January 2018 International Tax Lunch: Form 5472 Filing Requirements and Preparation

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January 25, 2018 - Rachel Allen

January 2018 International Tax Lunch: Form 5472 Filing Requirements and Preparation

Form 5472 Filing Requirements and Preparation

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: Debra Rudd

Materials: Dropbox

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December 26, 2017 - Rachel Allen

December 2017 International Tax Lunch: Irrevocable Trusts for Real Estate

Irrevocable Trusts are the Best Way to Own Real Estate (If You Are a Foreign Investor)

Irrevocable trusts offer the best of all possible worlds for tax efficiency: long-term capital gain tax rates when real estate is sold and protection from estate tax for the trust’s assets. This session will show how irrevocable trusts (foreign or domestic) can be used by nonresident purchasers of U.S. real estate, whether for personal use or for investment.

Presenter: Phil Hodgen

Materials: Dropbox

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December 22, 2017 - Rachel Allen

November 2017 International Tax Lunch: PFIC Tests In-Depth for Operating Companies

PFIC Tests In-Depth for Operating Companies

When U.S. ownership of a foreign corporation is—at most—50%, the foreign corporation, though an operating business, may fall under a special, punitive classification called passive foreign investment company. Learn in depth how to analyze the foreign corporation’s income and assets to determine whether the foreign corporation is—or is at risk of becoming—a PFIC.

Presenter: Haoshen Zhong

Materials: Dropbox

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December 22, 2017 - Rachel Allen

October 2017 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: Debra Rudd

Materials: Dropbox

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September 21, 2017 - Rachel Allen

September 2017 International Tax Lunch: Foreign Grantor Trusts

Foreign Grantor Trusts: When to Use Them and How To Do the Tax Compliance

Trusts are great for transferring wealth from one generation to the next. But when that transfer is from a nonresident to a U.S. resident, there are a number of competing factors for how to make that transfer happen. This session talks about classic foreign parent/U.S. child estate planning for foreign assets, using foreign grantor trusts for income tax and estate tax efficiency. Also, cover the tax compliance required during the parents’ lifetimes and after they die.

Presenter: Phil Hodgen

Materials: Dropbox

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