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March 2018 International Tax Lunch: Treaty Election for Nonresident Status

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March 27, 2018 - Rachel Allen

March 2018 International Tax Lunch: Treaty Election for Nonresident Status

Making the Treaty Election for Nonresident Status: When and How to Do It

Income tax treaties allow some taxpayers (if they meet the requirements) to convert themselves from resident alien status to nonresident alien status for income tax purposes. Learn about these treaty provisions called “tie-breaker rules” and find out who can use them. Identify how do the treaties work and how do you prepare Form 8833 to claim nonresident status.

Presenter: Phil Hodgen

Materials: Dropbox

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February 15, 2018 - Rachel Allen

February 2018 International Tax Lunch: Pensions as Foreign Trusts

Pensions as Foreign Trusts

U.S. citizens and foreign persons who immigrate to the U.S. often have foreign pensions. The U.S. tax law does not accommodate foreign pensions well, with the result that many of these pensions do not give tax deferral. Learn to recognize when a foreign pension fails to provide tax deferral and the U.S. tax and reporting consequences.

Presenter: Haoshen Zhong

Materials: Dropbox

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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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