International Tax Law Blog
by Phil Hodgen / 05.07.2024
The Punchline Form 5471 is required for an individual who is a resident alien and claims U.S. nonresident status because of an income tax treaty. This is true even though subpart F income and global intangible low-taxed income reported by way of that Form
by Phil Hodgen / 21.06.2024
This discussion is inspired by a question I got from Marissa M., so thank you for that. 🙂 Her question was not what I discuss here, but it reminded me of a problem that pops up again and again. Summary Here’s what happens. A
by Phil Hodgen / 07.06.2024
This week’s newsletter The May 31, 2024 International Tax Lunch webcast covered foreign investors in U.S. real estate and specifically the use of corporate structures to hold the real estate assets. Joshua Maya, a frequent correspondent, asked a question about personal holding company tax
by Phil Hodgen / 24.05.2024
Basis Step Up for Foreign Assets – How and Why It Works This newsletter is about stepped-up basis for foreign assets inherited by a U.S. taxpayer from a deceased non-U.S. person. Foreign asset, foreign owner who dies, the U.S. tax system never touches the
by Phil Hodgen / 13.05.2024
Reader’s Question about CFC Strategies This week is a quick break from the FIRPTA content, to answer a reader question about CFCs. An American living abroad owns 100% of a CFC. Here is the question. All the information I find is about deferral but
by Phil Hodgen / 26.04.2024
This week’s article is a request for you to email me and say “Oh, you’re so wrong Phil.” “So, so wrong.” (Walks away, shaking head sadly). Tell me I’m wrong. It’s a question about tax deductions for a C corporation when the shareholder lives
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