Category Archives: Taxation

Changes to Puerto Rico’s Act 20 and Act 22

On July 11, 2017, major changes to Puerto Rico’s Act 20 and 22 were approved. These changes make it much easier to qualify for Puerto Rico’s Act 20 tax holidays. Here’s everything you need to know about the changes to Puerto Rico’s Act 20 and Act 22. As of July 2017, Puerto Rico has a

perpetual traveler

Under the US tax code, a perpetual traveler is a US citizen or green card holder living outside the United States who doesn’t becomes a tax resident of another country. Being labeled as a perpetual traveler limits how many days you can spend in the US and can cause all kinds of problems for expats.

Tax Planning for an International Bank License

Tax planning for an international bank license is the most overlooked issue in startup banks. Sure, most offshore jurisdictions don’t tax your profits, but other countries will be looking for their cut if you set up an office or hire employees outside of your licensing jurisdiction. Here’s what you need to know about tax planning

Foreign Base Company Service Income

In this article I’ll explain how to eliminate Subpart F Foreign Base Company Service Income issues in an offshore corporation.  Subpart F issues are the most common tax planning hurdles to overcome when you have a division of a US company operating abroad. Subpart F applies to income of a Controlled Foreign Corporation (CFC). This

IRS Offshore Voluntary Disclosure Program

The IRS Offshore Voluntary Disclosure Program for 2017 offers taxpayers with undisclosed offshore accounts the ability to come forward voluntarily, file their returns, disclose their assets, pay the resulting taxes and penalties, and receive a clean slate. This article covers amendments to the Offshore Voluntary Disclosure Program through February 9, 2017. As of 2017, the

EB-5 Investor Visa
03/31/2017 - 4:29 PM
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The US EB-5 investor visa is one of the lowest cost residency to citizenship programs on the planet. Yes, you heard me right… you can buy US citizenship for a fraction of the cost of other top countries. Here’s how the EB-5 investor visa is going to change in 2017 and why it will still

how to report foreign salary

Here’s how to report a foreign salary or international business income. If you earn money from working as an employee or independent contractor, you need to report it on your US tax return. Here’s how to report income paid by a foreign company. I’ll briefly comment on income earned from abroad while living in the

Trump Tax Plan for Expats

Most of Trump’s tax plans will help American expats. If you’re living abroad, and making more than the Foreign Earned Income Exclusion, or have significant capital gains, Trump might cut your US taxes significantly. First, I should point out that there’s been no indication Trump will attack the FEIE. I don’t expect this Exclusion to

subpart f income
01/16/2017 - 4:19 PM
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When a US citizen forms an offshore corporation in a low tax country different from his country of operation, he has a Controlled Foreign Corporation with possible Subpart F income issues. In this article, I’ll review the Subpart F rules and determining factors. First, let’s talk about a Controlled Foreign Corporation. Subpart F only applies

self employment tax

If you’re living abroad and paid by a US company, you’ll pay self employment tax on your earnings. If you’re living offshore and operating a business without an offshore company or LLC, you’ll pay self employment tax on your profits. Here’s how self employment tax works when you’re offshore and how to avoid it. All

Which Countries Tax Worldwide Income?

When you’re planning a move abroad, you need to consider the tax laws of your country of citizenship and your country of residence. The key to a solid expat move is to determine which countries tax worldwide income and avoid them whenever possible. There are four basic tax groupings of countries. I won’t consider the

OECD tax exchange

As of November 2016, most offshore jurisdictions have signed on to the Automatic Exchange Agreements demanded by European governments and the Organisation for Economic Co-operation and Development (OECD). All but Panama has agreed to share information with European tax authorities. On paper, the OECD defines itself as follows: “the mission of the Organisation for Economic

software development

Puerto Rico has the best tax deals available to Americans… period. No offshore jurisdiction can compete with the US territory of Puerto Rico when it comes to cutting your taxes. This post will focus on Puerto Rico’s research and development and intangible property tax breaks. Act 73 is for those who develop licensed or patented

retained earnings

According to the N.Y. Times, The IRS has begun tracking homes bought through offshore companies and shell corporations in the United States. If you’ve setup an offshore structure, and used your retained earnings to buy real estate in the United States, you’re probably a target of the IRS. Even if your offshore company is tax

IRA when you give up US citizenship

Thousands of Americans will turn in their blue passports in the next few months. Some because of our crazy political climate, some to stop paying taxes into a broken system, and some because of FATCA and the international banking laws which make it impossible to live or do business abroad. This post will consider what

Pre-Immigration Tax Planning

If you’re moving the the United States, get ready for our crazy tax system. Most importantly, if you will become a US resident, be prepared for US tax on your worldwide income. You need to do your pre-immigration US tax planning before you arrive to minimize these taxes. Let me begin by defining what I