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November 2016 International Tax Lunch: Selling Goods Across the US Border

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November 14, 2016 - Rachel Allen

November 2016 International Tax Lunch: Selling Goods Across the US Border

Selling Goods Across the US Border

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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November 14, 2016 - Rachel Allen

October 2016 International Tax Lunch: The Portfolio Interest Exception: All Secrets Revealed

The Portfolio Interest Exception: All Secrets Revealed

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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October 11, 2016 - Rachel Allen

April 2016 International Tax Lunch: Tax Planning for Foreign Service Providers with U.S. Clients

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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October 11, 2016 - Rachel Allen

May 2016 International Tax Lunch: PFIC Tests in Depth for Operating Companies

PFIC Tests in Depth for Operating Companies

The passive foreign investment company (PFIC) rules are mechanical tests.  An operating company that is actually doing business can fall afoul of them in the right circumstances.  This session discusses some of the circumstances that may make an operating company a PFIC and what to spot to see if they are PFICs.

Presenter: Haoshen Zhong

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October 11, 2016 - Rachel Allen

July 2016 International Tax Lunch: How To Use Nongrantor Trust Structures For Foreign Investment In U.S. Real Estate

How To Use Nongrantor Trust Structures For Foreign Investment In U.S. Real Estate

Nongrantor trusts (foreign or domestic) have significant tax advantages for foreign investors in U.S. real estate. But these tax advantages come at a cost. Trusts are complicated and expensive to set up and operate. The investor loses control over the trust assets. The capital — and the capital gain — now belongs to the trust, not the investor.

In this one-hour session, Phil will walk you through a typical real estate holding structure for a foreign investor. When do you select a foreign or domestic trust? How do you design the trust for the desired tax results?... continue reading