Field Guide: Form 5471 Category 5a, 5b, or 5c? (Notice 2019-40)
I have been in New York this week to speak at the NYSSCPA’s International Tax Conference. The topic: filing categories for Form…
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Field Guide: Form 5471 Category 3 Filing Requirement Analysis
Today, I’m trying something different. Let me know what you think. Field Guide: The Idea About 18 months ago, Cameron Ware and…
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Form 5471 Penalty Litigation Demonstrates how Federal Courts Work
Form 5471 penalties are still in business By now, you have undoubtedly heard about the Farhy v. Commissioner case: a Tax Court…
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Check-the-Box Election and Self-Employment Tax
Background Making the check-the-box election for a foreign operating business will make sense for many people. Certainly, it eliminates the dreaded Form…
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Despite What the IRS Thinks, Form W-8CE has No Filing Deadline
A quick expatriation topic for you. Covered expatriate defined Covered expatriates are U.S. citizens or long-time green card holders who terminate that…
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Form 5471 Category 1 Rarely Applies, and Never* for a New U.S. Resident
Typical scenario A nonresident owns 100% of a foreign corporation’s stock. Neither the shareholder nor the foreign corporation have any contact with…
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How To Make Domestic Corporation Stock Not be a USRPI
International Tax Insiders Just dropping it here: if you want to join a group of international tax pros, maybe you’ll want to…
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Deduction or Capitalization of Carrying Costs for U.S. Real Estate
Nonresident Owns a U.S. House The scenario is a common one: a nonresident individual owns a house in the United States. Having…
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Don’t Forget Section 367(b) when Working with Foreign Corporations
Summary I engineered a Section 368(a)(1)(D) reorganization in 2023 involving two CFCs. Form a new corporation, contribute the stock of OldCo to…
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Branch Profits Tax for Rental Income
This week I am writing about how rental income is taxed for nonresident investors in U.S. real estate, and when using a…