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In this month’s tax lunch presentation, we will work through a real world scenario where a US person buys into a foreign mutual fund — which happens to be a PFIC — held in a foreign investment account. Over several years, he receives dividends (some of which are reinvested), some of his shares are redeemed to pay account fees, and finally, he sells all his shares in the PFIC.
We will cover the real calculations in detail, including running basis as the share holdings change over time, excess distributions, tax, and interest.... continue reading
Presenter: Phil Hodgen
Everyone focuses on the income tax consequences of renouncing U.S. citizenship or giving up a green card. Am I a covered expatriate? Will I have to pay an exit tax?
Income tax and covered expatriate status is only part of the problem.
Many expatriates – covered or not – will continue to own U.S. assets after renouncing citizenship or abandoning their green cards. Real estate. U.S. stock, bonds, and mutual funds. Retirement accounts. These assets can create a U.S. estate tax problem.
If you will own U.S. assets after you expatriate, listen in as Phil describes the tax rules, your exposure to estate tax risk, and what you can do about these risks – both before and after expatriation.... continue reading
Presenter: Haoshen Zhong
Suppose you are a foreign manufacturer or exporter, and you want to sell your goods in the US. What federal tax considerations are there? Suppose you are a US manufacturer or exporter, and you want to sell your goods outside the US. What tax planning can you do?
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Presenter: Phil Hodgen
Foreign lenders can make mortgage loans on U.S. real estate and collect the interest tax-free. This month, Phil talks about the portfolio interest exception. Why does it work? How does it work? Phil will demystify the magic language that must be included in the loan documents, and emphasize practical tips to follow when you are setting up such a loan. A sample promissory note template is included with the slides.
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Tax Planning for Foreign Service Providers with U.S. Clients
You are a non-U.S. consultant, web developer, programmer, or other service provider, and you are hired by a U.S. client.
This month’s International Tax Lunch walks you through the U.S. tax laws that apply to you. What will you pay? What paperwork will you file? What can you do to reduce or eliminate tax, paperwork, or both? We will discuss using transfer pricing techniques — they can work, even micromultinational businesses, like a one-person service provider.
Presenter: Phil Hodgen
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