December 1, 2015

What are the Mixed Sourcing rules?

INCOME FROM MIXED SOURCES Some income may have multiple sources. The rule varies according to the type of income-producing asset. INVENTORY SALES: GENERAL RULES There are […]
March 26, 2014

US citizen living abroad. Concerned about increasing taxes

ACCORDINGLY, I AM CONSIDERING RELINQUISHING MY U.S. CITIZENSHIP (OR PERMANENT RESIDENT STATUS). IS THIS A GOOD IDEA? The decision to relinquish your U.S. Citizenship or Permanent […]
March 26, 2014

Can I abandon green my card for tax purpose

Certain formal requirements must be satisfied to abandon one’s green card. Specifically, the abandonment of a green card will not terminate the alien’s resident alien status […]
March 25, 2014

Recent international tax and reporting prosecutions

Igor Purlantov, a New York attorney, pleaded guilty and was sentenced to 24 months in prison for fraudulently transferring more than $1 million from the bank […]
March 25, 2014

Basic Tax Rules for Passive Foreign Investment Companies

The rules governing Passive Foreign Investment Companies (“PFICs”) are a bit similar to the rules for CFCs. Shareholders of a PFIC are subject to the undistributed […]
March 25, 2014

What is the “Deemed Paid” Foreign Tax Credit?

Typically, to receive the FTC, the U.S. taxpayer must have actually paid the foreign tax. But there is an exception to this rule. If a U.S. […]