International Tax Law Blog
by Phil Hodgen / 21.03.2025
When you have to file Form 5471 and Form 5472 Sometimes you have a situation where you need to prepare both Form 5471 and Form 5472. Here is a discussion of an exception that allows you to eliminate Form 5472. Example: a U.S. citizen
by Phil Hodgen / 07.03.2025
This is The Friday Edition—international tax information for international tax professionals, written by mygoodself, Phil Hodgen. In my day job I’m an international tax lawyer. Today I give you a little bit of practical FIRPTA goodness when you have a nonrecognition transfer of U.S.
by Phil Hodgen / 24.02.2025
I am working on the Category 4 Field Guide and had a TIL moment, and I’m going to share it with you: the family attribution rules of IRC Section 318(a) have a weird and unexpected (for me) asymmetry. This week, I was one of
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
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
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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