October 30, 2015 - Phil Hodgen

Upcoming events and moments of “huh?”

Hi, it's Phil, and greetings from beautiful Oakland International Airport. You signed up for my Friday Edition newsletter, and here it is. If you want to stop getting it, click on the unsubscribe link at the end of this email. Or, if you want more email, subscribe to one of our other wonderful lists, at

This week is a quick one.

International Tax Conference – November 6

I am the chairman of the CalCPA International Tax Conference again this year. Please attend — in person or online.

You will hear many wonderful things, including Debra Rudd, CPA from our team, who will be speaking about PFICs. (Subscribe to her PFIC newsletter, too, if you love the topic.)

The event is on Friday, November 6, 2015. If you can come the night before, I will be once again warming up the credit card and paying for adult (and other) beverages in the hotel bar at the Hyatt Regency in San Francisco.

If you are interested in being a speaker at next year's Conference, drop me a line and let's talk. We look for people who are masters of their topic, and are excellent public speakers. We do not want book knowledge. We want practitioners — people who are doing this stuff day in and day out. Dan Andrews calls them preacher-practitioners. Subscribe to his podcast, by the way.

Texas International Tax Conference – November 12, 13

I am speaking at the Texas International Tax Conference in Dallas and Houston on November 12 and 13, 2015. The topic? Expatriation. We just came off a record quarter for people giving up U.S. citizenship. It's the popular thing to do.

The more you know, the more you forget . . .

I am reminded of a poem I first heard as a kid:

The more you study,
The more you know.
The more you know,
The more you forget.
The more you forget,
The less you know.
So why study?

I sometimes feel that the longer I do this stuff, the less I really know. I am constantly coming up short and saying "Huh?" to myself. I have frequent lunches with Rufus Rhoades and he, of encyclopedic tax knowledge, is constantly coming to those "Huh?" moments, too.

On the other hand, many, many things which once baffled me are now intuitively obvious. So maybe I have just shifted my bafflement to different places in the Internal Revenue Code. 🙂

I just finished up my one-day Taxation of Multinational Families course for CalCPA in San Mateo. In fact, that's the cause of my visit to mighty Oakland Airport.

It is increasingly harder for mere humans to move across borders and keep the tax rules straight. That is all we do, day in and day out, so we can stay more or less on top of things. I have a lot of experience with individuals and families investing from the Middle East and Asia — their money or their family members (or both) coming to the United States for a short or long stay.

It's a moving target. Other countries are getting more and more aggressive, emulating the United States. For instance, I have fairly deep experience with Indonesia. It isn't always easy to predict the result of a particular action when considering the interaction of U.S. and Indonesian law.

Which probate rules will apply at death? How are things taxed? No really! I know what the rules are but how are they applied by tax authorities with wide latitude in enforcement and interpretation?

The day I just spent at CalCPA World Headquarters in San Mateo helps me organize these thoughts. There is nothing like standing up in front of a crowd to make you understand stuff you thought you knew. And to reinforce how little you actually know.

That's it for now. See you in a couple of weeks.


Friday Edition