Introduction to Controlled Foreign Corporations

Introduction US persons are taxed on their worldwide income.  Normally, a US person who owns shares of a foreign corporation will only recognize income when and to the extent that the foreign corporation pays dividends to the US person.  Many years ago, US persons seized upon this, formed their...

Foreign Earned Income Exclusion for US Persons

Introduction US persons are taxed on their worldwide income. As a matter of public policy, when a US person has foreign-sourced income, the United States seeks to avoid the double-taxation of that income. That is, Congress does not want the US government to impose taxes on top of a...

Medicare Benefits Abroad

Does your Medicare Coverage cover you while you are living or traveling abroad? Unfortunately, the answer is most likely going to be no. Original Medicare Coverage includes all 50 states, and U.S. territories (U.S. Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands), but outside of those locations,...

An Introduction to Currency Taxation

A basic understanding of currency exchange principles is critical for U.S. expatriates, international business people, and global investors. U.S. tax liability is determined in U.S. dollars. Because currency values change relative to one another, many tax issues arise when currencies are bought and sold. Last month, we discussed general...

Why The “Tax Holiday” For Corporations Is Bad

Some U.S.-based corporations have business operations outside the United States.  Often, those non-U.S. operations are conducted by subsidiaries of the U.S. firm.  Those subsidiaries are typically organized in the jurisdiction in which they operate.  The income of each non-U.S. subsidiary is taxed by the jurisdiction in which it derives...