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Passive foreign investment companies (PFICs) have a notoriously punitive tax treatment. Fortunately, there are two different elections that may be made to reduce tax. Learn how the Mark-to-Market and QEF elections can provide a better tax result than the default treatment, when those elections may be used and how to perform the necessary calculations and prepare Form 8621.
Presenter: Debra Rudd
Materials: Dropbox
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A foreign corporation may wish to invest in U.S. real property. A common holding structure is to have the foreign corporation organize a U.S. limited liability company, then use the LLC to acquire the property without electing to treat the LLC as a corporation. Learn how the U.S. taxes the foreign corporation’s rental income and gains from the sale of the U.S. real estate.
Presenter: Haoshen Zhong
Materials: Dropbox
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What do you do when you need to report a PFIC but lack the necessary information to do so? This is a common scenario for PFICs held in foreign tax-deferred accounts that are not deferred in the US, or when a taxpayer has held a PFIC for many years and no longer has all of the records. This presentation will discuss what data is needed when completing Form 8621, what issues may arise as a result of not having complete data, and strategies for preparing Form 8621 with partial data.
Presenter: Debra Rudd
Materials: Dropbox
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In this month’s International Tax Lunch, Phil will walk you through the preparation of an income tax return for a U.S. beneficiary of a foreign nongrantor trust. You will learn how how to identify a trust distribution, then how to prepare Form 3520 and Form 4970, and where the numbers go on the beneficiary’s Form 1040.
Presenter: Phil Hodgen
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Suppose you are a US citizen and the owner of a popular consulting business. You have clients all over the world. You provide consultations for a fee, and you sell recordings of your seminars and publications. Is there any way you can leverage a foreign corporation to defer US tax on the income, so you have more resources to expand? What are the costs of deferral?
Who: Haoshen Zhong
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