by Phil Hodgen / 10.02.2025

I get emails . . . and one of them gave me the idea for this newsletter. In many parts of the world (Central America is what I usually see) it is common to own real estate in a corporation–including your house. For a

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When Your House is Owned by a Corporation, Central American-style

by Phil Hodgen / 24.01.2025

I have been in New York this week to speak at the NYSSCPA’s International Tax Conference. The topic: filing categories for Form 5471. A new Form 5471 Field Guide One of the side effects of that speech: another Field Guide. This one is for

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Field Guide: Form 5471 Category 5a, 5b, or 5c? (Notice 2019-40)

by Phil Hodgen / 10.01.2025

Today, I’m trying something different. Let me know what you think. Field Guide: The Idea About 18 months ago, ​Cameron Ware​ and I were talking. He offered up an idea to make his tax season more efficient: tax publications written with the Pareto Principle

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Field Guide: Form 5471 Category 3 Filing Requirement Analysis

by Phil Hodgen / 20.12.2024

Form 5471 penalties are still in business By now, you have undoubtedly heard about the Farhy v. Commissioner case: a Tax Court taxpayer win (the IRS cannot assess Form 5471 penalties), and an Appeals Court reversal (the IRS can, indeed, assess Form 5471 penalties).

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Form 5471 Penalty Litigation Demonstrates how Federal Courts Work

by Phil Hodgen / 15.11.2024

Background Making the check-the-box election for a foreign operating business will make sense for many people. Certainly, it eliminates the dreaded Form 5471, and simplifies U.S. tax compliance. But it may come with an added and unexpected tax cost: self-employment tax in the United

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Check-the-Box Election and Self-Employment Tax

by Phil Hodgen / 05.11.2024

A quick expatriation topic for you. Covered expatriate defined Covered expatriates are U.S. citizens or long-time green card holders who terminate that status and are either: “Bad”–their tax obligations were not fully satisfied for the previous five years, or “Rich” – they have net

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Despite What the IRS Thinks, Form W-8CE has No Filing Deadline