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December 2019 International Tax Lunch: Inbound Executives of Foreign Corporations

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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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October 25, 2019 - Rachel Allen

October 2019 International Tax Lunch: Foreign Corporation Information Reporting—Form 5471 and Attribution Rules

Foreign Corporation Information Reporting—Form 5471 and Attribution Rules

When a U.S. person owns interest in a foreign corporation or has some other relation with a foreign corporation, they may need to file an information return: Form 5471. Learn the conditions under which Form 5471 is required, attribution rules and what is required.

Presenter: Debra Rudd

Materials: Dropbox

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September 24, 2019 - Rachel Allen

September 2019 International Tax Lunch: Guide to Global Intangible Low-Taxed Income

Guide to Global Intangible Low-Taxed Income

U.S. shareholders of foreign corporations have a new pass-through income category to contend with: GILTI. Except for capital-intensive companies, this has the effect of making foreign operating income immediately taxable to U.S. shareholders.

This session explores the new rules. What is GILTI? How will it affect U.S. shareholders? What countermeasures are available?

Presenter: Phil Hodgen

Materials: Dropbox

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July 25, 2019 - Rachel Allen

July 2019 International Tax Lunch: Accumulation Distribution From A Foreign Nongrantor Trust

How To Report An Accumulation Distribution From A Foreign Nongrantor Trust

When a U.S. beneficiary receives a distribution from a foreign trust, the way the distribution is taxed depends on whether the trustee gives the beneficiary the right paperwork. This presentation looks at the all-too-common scenario where a trustee does not provide the necessary paperwork to prevent bad tax results. Learn how to calculate the accumulation distribution under the default rules, how to compute the tax to the beneficiary, and how to prepare the tax forms to report the distribution.

Presenter: Debra Rudd

Materials: Dropbox

... continue reading