August 11, 2016

A Citizenship Renunciation FAQ

All Expatriates Need to Know to Leave the United States Behind: As a U.S. citizen or long-term green card holder, you love your country or at […]
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 […]
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 […]
July 3, 2015

What Actions of Foreign Persons Affect U.S. Tax Attributes?

In limited circumstances, U.S. tax attributes are affected by the actions of foreign persons with no immediate physical presence in the United States. Consider the following […]
March 26, 2014

What is The Stop Tax Haven Abuse Act?

We answer these and other questions below. a. Definition of “tax haven” There is no precise definition of what a “tax haven” is, but it typically […]
March 26, 2014

Possible for a Domestic Trust to Become a Foreign Trust?

In a word, “yes”—it is possible for a domestic trust inadvertently to become a foreign trust. This is significant because that means different tax rules apply, […]