International Tax Law Blog
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
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
by Phil Hodgen / 18.10.2024
Typical scenario A nonresident owns 100% of a foreign corporation’s stock. Neither the shareholder nor the foreign corporation have any contact with the United States in the years before the nonresident comes to the United States. The nonresident commences resident alien in calendar year
by Phil Hodgen / 07.10.2024
International Tax Insiders Just dropping it here: if you want to join a group of international tax pros, maybe you’ll want to join us here: https://internationaltaxlaw.com/join/. How to make USRPHC stock not be a USRPI OK. This technical topic came from Elizabeth S. In
by Phil Hodgen / 20.09.2024
Nonresident Owns a U.S. House The scenario is a common one: a nonresident individual owns a house in the United States. Having purchased it, what will happen next? Well, the new owner will do one of the following: House Sits, Empty. Leave the house
by Phil Hodgen / 13.09.2024
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 NewCo, liquidate OldCo into NewCo, and dissolve OldCo. In thinking about the tax compliance for such a transaction, it’s easy to focus
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