Skip to content 
A Foreign Non-Grantor Trust (FNGT) is a type of trust established under the laws of a foreign (non-U.S.) jurisdiction, where the person creating the trust (the grantor or settlor) does not maintain control over the trust’s assets or income for U.S. tax purposes. This means that the grantor is not treated as the owner of the trust’s […]
What is a PFIC? PFICs is a really complex area of international tax law. Special care is needed. For those who are new to this topic? Please scroll down to read my article below. If however, you are a more sophisticated investor, we discuss PFICs in the context of 1. Australia funds – – https://htj.tax/2021/07/us-taxation-of-australian-superannuation-funds/
The Ultimate Guide to PFICs Read More »
Up until the US invasion in 1989, Panama was the premier off-shore jurisdiction but the BVI came to prominence after that event. The British Virgin Islands (BVI) is often called the grandfather of all IBCs. IBC stands for “international business company,” originally from the International Business Companies Act of 1984 in the British Virgin Islands.
The Ultimate Guide to a Company in the BVI Read More »
Most states in the United States define “residency” based on a person’s “domicile.” Domicile, in general, is the place which an individual intends to be his or her permanent home and to which such individual intends to return whenever absent. Here’s something we wrote on domicile previously, but in the context of pre-immigration tax planning and
As an Expat, How do I Change my State Tax Domicile? Read More »
What does filing an “extension” do? An extension is a form filed with the IRS to request additional time to file your federal tax return. The extension period is six months, extending the due date for submitting your individual return to Oct. 15.* In many states, filing an extension with the IRS will automatically extend
My Tax Team says, ‘extend.’ What does that mean to me? Read More »
Who Are Residents and Nonresidents A resident is any individual who meets any of the following: Present in California for other than a temporary or transitory purpose. Domiciled in California, but outside California for a temporary or transitory purpose. A nonresident is any individual who is not a resident. A part-year resident is any individual
Am I a California Resident for Tax Purposes? The Ultimate Guide Read More »
RE: Corporate Transparency Act — Beneficial Ownership Information Reporting Requirement Dear Sir / Madam, Starting January 1, 2024, a significant number of businesses will be required to comply with the Corporate Transparency Act (“CTA). The CTA was enacted into law as part of the National Defense Act for Fiscal Year 2021. The CTA requires the
Corporate Transparency Act — Beneficial Ownership Information Reporting Requirement Read More »
Private equity describes investment partnerships that buy and manage companies before selling them. Private equity firms operate these investment funds on behalf of institutional and accredited investors. Private equity funds may acquire private companies or public ones in their entirety or invest in such buyouts as part of a consortium. They typically do not hold stakes in companies that remain listed on a stock exchange. Private equity is
Pro Forma Schedule K-1s vs Qualified Electing Fund Letter for Singapore VCCs Read More »
This type of “limited silent partnership” entity exists in civil law countries such as Argentina, Brazil, Chile, Colombia, Mexico, Portugal, Spain, and Venezuela. The basic elements of a Sociedad en Comandita por Acciones (S.C.A.) or a Sociedad en Comandita Simple are similar to those of an S.A. However, one difference between the S.A. and S.C.A.
The Comandita (S.C.A.) Read More »
Then there is the passive foreign investment companies exit tax, which some have called the “stealth exit tax.” Under proposed regulations, this tax applies to anyone (including those who are US persons only by the substantial presence test), regardless of wealth, who changes status from US person to nonresident. I would argue that the PFIC
Stealth Exit Tax — PFICs Read More »