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Archive for 'Foreign Corporations' Category

So, Sir Patrick Stewart Wants to Become a US Citizen?

By Virginia La Torre Jeker J.D., - Sunday, March 12, 2017

Sir Patrick Stewart (yes, despite rumors to the contrary, I know you are still alive), I understand you want to become a US citizen so you can “fight” President Trump (in your… Read more…

IRS Has a New Audit Strategy – Focus OVDP Withdrawals and Declines

By Virginia La Torre Jeker J.D., - Sunday, March 5, 2017

Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division now has a new audit strategy known as “campaigns.” For the past several years, the LB&I Division has attempted to… Read more…

House Republicans – Death Knell for Subpart F/ Americans Abroad Barely Acknowledged

By Virginia La Torre Jeker J.D., - Monday, January 16, 2017

House Republicans set out to deliver a bold, pro-growth policy agenda focused on addressing important concerns of the American people which included how changes to the tax law could grow… Read more…

PFIC Break for Some – No Need to File Annual Form 8621

By Virginia La Torre Jeker J.D., - Monday, January 9, 2017

Heartfelt thanks to Richard S. LeVine, J.D., LL.M. who emailed me to point out that the Internal Revenue Service (IRS) had just recently issued final “Passive Foreign Investment Company” (PFIC)… Read more…

Foreign Corporations Spared in IRS Final “Debt” / “Equity” Regulations

By Virginia La Torre Jeker J.D., - Friday, November 4, 2016

Code Section 385 deals with the classification of certain interests in corporations as either “debt” or “equity” interests. The Code Section was originally enacted over 40 years ago, and later amended… Read more…

Do I Hold “Debt” or “Equity” in a Foreign Corporation? (Factors, Part II)

By Virginia La Torre Jeker J.D., - Saturday, September 10, 2016

My last two blog posts, here and here, examined some of the tax consequences that could occur when a taxpayer mistakenly classifies an advance to a foreign corporation as a… Read more…

Do I Hold “Debt” or “Equity” in a Foreign Corporation? (Factors, Part I)

By Virginia La Torre Jeker J.D., - Friday, September 2, 2016

My earlier blog post detailed some of the tax consequences that could occur when a taxpayer makes, what he thinks is a “loan” to a foreign corporation, but that the Internal Revenue… Read more…

Your “Loan” to a Foreign Corporation

By Virginia La Torre Jeker J.D., - Wednesday, August 24, 2016

What happens if you make a loan to a foreign (non-US) corporation and the Internal Revenue Service (IRS) later determines that the “loan” should not be treated as a “loan”… Read more…

“Cash” Buyers of US Real Estate – More Under FinCEN’s Microscope

By Virginia La Torre Jeker J.D., - Wednesday, August 17, 2016

Last year, FinCEN started to look more closely at anonymous cash buyers of prime US real estate. The agency’s concern was that real estate purchases made without bank financing through… Read more…

Expatriation SNAFU! Form 5471 Not “Substantially Complete”

By Virginia La Torre Jeker J.D., - Wednesday, July 6, 2016

My earlier blog posting covered some of the basics of Form 5471, “Information Return of U.S. Persons with Respect to Certain Foreign Corporations”.  The Form is notoriously complex and consumes… Read more…

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An up-to-date look at US tax laws for American Expats, foreign investors into the US market or other foreign persons having any US connections. More Info

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