November 9, 2015
tax planning for foreign corporations

Potential Tax Liabilities of a Foreign Trust or Estate

Are foreign trusts and estates subject to U.S. Estate and Gift taxes? The short answer: sometimes. The U.S. taxation on the transfers of property by a […]
July 3, 2015

Foreign corporations taxed on their U.S. source income

Regulation § 1.6012-2(g)(1) requires foreign corporations that are viewed under the IRC to be engaged in ongoing U.S. trade or business activity to file Form 1120-F […]
March 26, 2014

Can you avoid the Exit Tax prior to expatriating from U.S.

Possibly. It is often very difficult to entirely remove oneself from the U.S. tax system, but with proper exit planning the associated tax bite can be […]
March 26, 2014

What is the scope of the Exit Tax?

The Exit Tax includes both an income tax and an inheritance tax element. The income tax element consists of a deemed “mark‐to‐market” tax on the inherent […]
March 26, 2014

Tax consequences if I decide to immigrate to the U.S.?

Yes, there are income tax and transfer tax (gift, estate, and generation‐skipping transfer) consequences to obtaining U.S. Citizenship (or Permanent U.S. Resident Status). Careful consideration should […]
March 25, 2014

Why is foreign tax credit allowed?

Do I have to use a certain accounting method (cash vs. accrual)? The foreign tax credit is allowed for foreign income taxes that are “paid or […]