Are "non-U.S. mutual funds" foreign corporations AKA #PFIC? Does your tax preparer know for sure?

Why Australian managed funds are a poor choice for Australian-resident US taxpayers… — Fix the Tax Treaty! (@FixTheTaxTreaty) July 3, 2017 I have written many posts that include a discussion of PFICs. This post has been motivated by a post by Karen Alpert at “Fix The Tax Treaty” (well it can’t really be fixed). […]

Green card holders: the "tax treaty tiebreaker" rules and taxation of Subpart F and PFIC income

Before you read this post!! Warning!! Warning!! Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on: A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?) B. His/her status under Title 26 […]

Interview with – Citizenship based taxation, PFIC, the S. 877A Exit Tax and #Americansabroad

US "citizenship" taxation, #PFIC, US 877A Exit Tax, #Americansabroad, relinquish US citizenship @Expatriationlaw — Citizenship Lawyer (@ExpatriationLaw) May 27, 2015 On May 22, 2015 I was interviewed by Gordon T. Long. There is NO way to discuss U.S. “citizenship taxation” (which is primarily “place of birth taxation”) without discussing the S. 877A Exit Tax […]

If (U.S. Person) then (Mr. #FBAR Ms. #PFIC and Uncle #FATCA) = Few investment and financial planning opportunities).

U.S. #Expat Tax Conference – Toronto – November 13, 14/14 – Opportunity to meet Mr. #FBAR Ms. #PFIC and Uncle #FATCA — Citizenship Lawyer (@ExpatriationLaw) September 22, 2014 Deborah Hicks International – U.S. Expat Tax Conference – November 13, 14/2014 Toronto. US expat tax and finance conference Toronto 2014 leaflet This conference is similar […]

Fidelity joins MacKenzie to make ownership of #PFIC mutual funds more tolerable for Canadians

Fidelity CA takes lead in Cdn fund industry by making it possible for investors to make QEF election for #PFICs – — Citizenship Lawyer (@ExpatriationLaw) February 21, 2014 MacKenzie to provide Cdn fund investors with information to file IRS #PFIC forms – Smart business move! — Citizenship Lawyer (@ExpatriationLaw) February 21, 2014 A […]

PFIC taxation and Americans abroad

This post was originally written in February of 2014. It has been updated September 11, 2020 First, giving credit where credit is due … A superb “Readers Digest” summary of how the PFIC rules are understood to apply to individuals was prepared by PWC in 2017. You will find the report here and here: pwc-united-states-pfic-guidance-provides-new-reporting-exceptions […]

The Beyer “Tax Simplification For Americans Abroad Act”: A First Look

Updates November 22, 2021: 1. I have also written a post on the SEAT site which compares (in a general way) the Beyer Bill of 2021 to the Holding Bill of (2018). Any attempt to solve this problem through amending the FEIE actually has the effect of strengthening citizenship based taxation. 2. With respect to […]

Take 1: Digging The Foundation To Build The House Of US Residency-based Taxation

Thanks to @Tpsmyth01 for help in "Take 1: Digging The Foundation To Build The House Of US Residency-based Taxation" – Hosting a zoom call to discuss proposal and related matters on Sat. July 10/21 at 8:00 am EST – Please DM to join via @expatriationlaw — John Richardson – lawyer for "U.S. persons" abroad […]

Treasury 26 CFR ยง 301.7701-2 – Business entity definitions discriminate against Canadian Controlled Private Corporations

Synopsis: The power to regulate is the power to destroy! That's why the regulatory process should require careful consideration of how and to whom regs apply. It's time for Treasury to consider "A Simple Regulatory Fix for Citizenship Taxation" via @SEATNow_org — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 27, 2021 […]