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 […]

July 5/22: An Opportunity To Educate Resident Americans About The Horrors Of Citizenship Tax

Updated July 5, 2022 … Great discussion with Bob Paxton and Bob Scarborough: Why #Americansabroad and @USVotersAbroad should be supporting the #FairTax and @FairTaxOfficial. Join @FairTaxAbroad! — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) July 6, 2022 An Opportunity To Educate Resident Americans About The Horrors Of US Citizenship Tax .@USVotersAbroad: An […]

As Goes The “Fairness Of Taxation”, So Goes Civilization: It’s Time To Consider The “Fair Tax”

Introduction #FairTax policy is good policy. Why @FairTaxOfficial means restoring "freedom and dignity of the individual" (as well as creating a "fairer" tax system). Imagine a world where #Americansabroad were no longer #GILTI and @citizenshiptax would be meaningless. — John Richardson – lawyer for "U.S. persons" abroad (@ExpatriationLaw) June 30, 2022 I was recently […]