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Explore our topics

Controlled Foreign Corporations

Taxation and tax paperwork required for U.S. shareholders, officers, and directors of majority U.S.-owned foreign corporations. Subpart F income, Global Intangible Low-Taxed Income. Form 5471.


U.S. citizens and long-time green card holders can terminate that status and leave the U.S. tax system permanently. Doing so creates tax paperwork (at a minimum) and may incur an income tax cost (at worst) in the form of the exit tax. Form 8854. 


Trusts -- whether formed in the U.S. or another country -- are a key tool for protecting a multinational family's wealth. U.S. tax paperwork is painful, and penalties are shockingly high. How do you use trusts? How do you fix a broken trust? Form 3520, Form 3520-A.

Nonresident Investment in U.S. Real Estate

U.S. real estate is an attractive investment asset for nonresidents. We talk about holding structures, buying, selling, tax-free exchanges, withholding. Income tax on rental income, capital gain tax on sale, and estate tax if the nonresident owner dies.

Hi, I'm Phil Hodgen

My team and I are practicing tax attorneys and accountants in Pasadena, CA. We help with some of the hardest and most sensitive tax issues.

Every other Friday, we also publish what we like to think is the most thoughtfully researched International Tax Newsletter in the world. Over decades of front-line experience, we’ve learned how the IRS thinks. We translate for you in our newsletter.