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Derren Joseph

Derren is a part of an international tax team that works with 6, 7 and 8 figure International Entrepreneurs, Expats and Investors to legally minimize their global tax burden and protect their wealth. Strategies include second citizenships, second residencies, trusts, foundations, insurance wrappers and other offshore structures.

Derren Joseph

Income Inclusions for U.S. Shareholders of Controlled Foreign Corporations (CFCs)

In the ever-evolving tax environment, many taxpayers and tax professionals are seeking guidance on the intricate international tax compliance and reporting obligations for U.S. shareholders of Controlled Foreign Corporations (CFCs). CFCs are entities that are majority controlled, directly or indirectly, by a U.S.-based parent company, but are incorporated under foreign law. For U.S. income tax

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Demystifying Form 1120-F: A Must-Read Guide for Foreign Corporations in the U.S.

Form 1120-F is a vital tax document for foreign corporations with business connections in the United States. This form acts as the U.S. income tax return for foreign corporations, summarizing the corporation’s income, gains, and losses. A Closer Look at the Purpose of Form 1120-F Form 1120-F, formally known as the U.S. Income Tax Return

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Assessment of Penalties on Substitute Forms 3520-A

In recent years, several clients have faced heavy penalties for the late filing of Form 3520-A, known as the “Annual Information Return of Foreign Trust With a U.S. Owner.” Surprisingly, these penalties were assessed even when clients had filed a timely substitute Form 3520-A. This practice by the IRS contradicts its own published guidance. Fortunately,

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Advanced Discussion on the Tax Treatment of Usufructs

Planning strategies that split a property into usufruct and bare ownership interests are common in civil law jurisdictions, serving various tax and non-tax goals. However, these divisions can pose challenges in common law jurisdictions, particularly in determining tax implications. When there’s no common law counterpart, authorities often resort to analogies with common law structures. The

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US Pre Immigration Tax Planning – February 2024

Does an EB-5 Offer the Same Green Card Benefits as an EB-2 or EB-3? These categories are ‘employment-based.’ However, EB-5 is an investment and job creation immigrant category, while EB-3 is for skilled or professional workers who have received an offer of permanent employment from a U.S. employer/sponsor. This employer/sponsor has applied to the U.S.

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Foreign Non Grantor Trusts as a Pre Immigration Tax Planning Tool to those migrating to the US

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

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The Ultimate Guide to a Company in the BVI

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. 

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