Category Archives: Uncategorized

The battle over U.S. corporate tax inversion – listen to @SenCarlLevin

Senator Carl Levin attempts to defend the right of the U.S. to tax profits earned outside the United States. The Senator doesn’t even once point out that:

1. Inversions do NOT affect the amount of tax paid on U.S. profits; and

2. Does NOT acknowledge that all inversions do is exempt U.S. companies from tax on foreign profits where they already pay tax to those countries.

Levin believes that tax reform is not likely.



The basics of #Americansabroad and inheritances – with a touch of expatriation

Anything to do with U.S. tax is of course complicated. That said here are some basic principles.

The basic principle – you can inherit free of U.S. tax

Whether a U.S. person is living inside or outside the United States:

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The special rules of U.S. Taxation and the non-U.S. spouse

The above tweet references a post from Jane Bruno about the U.S. tax implications  of the “non-American spouse” which includes in part:

If you are married to a non-American and you both live overseas, you may have wondered how this impacts on your U.S. tax filing situation, if at all. As with most concerns involving taxes, the more complicated they can make it, the better Congress likes it! This article will try to present your various tax obligations (and options) with regard to a non-American spouse as simply and precisely as possible.

Read on! To be forewarned  is to be forearmed!




Snowbirds beware! You can be a tax resident of both Canada and the U.S.

The topic of the day:

The problem revealed:

The reason as described by Ms. Jeker in the post:

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Recipients of gifts from covered expatriates must pay tax on gifts

Another great article from Virginia La Torre Jeker describes the reason for the taxation of gifts to U.S. citizens from “covered expatriates” as:

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@VLJeker Trilogy: Foreign Corporations – Dividends, qualified dividends and subpart F


Controlled Foreign Corporations and Subpart F income were introduced here. Tax professionals about written about the dangers of Americans abroad carrying on business through a corporation. In addition to the tax problems (dividends, Subpart F, etc). there are also extremely invasive, expensive and penalty laden reporting requirements. In fact, Form 5471 is arguably America’s most deadly and dangerous form.

For those who want to understand this difficult topic better …



Well, she has followed through. Form 5471 is the form required for “Foreign Corporations”. She has written this wonderful trilogy of posts on “Foreign Corporations”. Thank you Virginia La Torre Jeker for the following:

“What you need to know about foreign corporations, but couldn’t even imagine to ask “Triology”.

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The horrors of retirement planning for #Americansabroad – #PFIC edition


General discussion of how the PFIC rules work in theory:

Discussion of the incredible unfairness and stupidity of the PFIC rules in practice (don’t enter OVDP):

And a comment that says it all:

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Should it be reported on your #FBAR? Not even your accountant knows for sure

The deadline is fast approaching. Mr. FBAR has been updated and modernized.

He has a new name (Form 114).

He has a new look.

He must now be filed online.

He is still one of the U.S.A.’s deadliest forms.

But, the question still remains:

What exactly is required to be reported on your FBAR?

Taxpayers “navel gaze” in fear!

Tax professionals continue to educate!

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