Category Archives: Taxation

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
asset protection puerto rico

Once you have your Act 20 business in Puerto Rico up and running, you need to think about protecting its retained earnings or distributed profits. Asset protection for a Puerto Act 20 business  becomes urgent because of the amount of capital held in the company tax deferred. There are two levels of asset protection for
eb-5 visa

If you are thinking about coming to America, get ready for high taxes on your worldwide income. In this article, I will explain how to become a US citizen using the EB-5 Visa and Puerto Rico to pay near zero US taxes. The US taxes its citizens, as well as green card holders and residents,
IRS and panama papers

Do you have a company or bank account in Panama? Are you wondering if you should be worried about the IRS and Panama Papers? Do you know that the searchable database of Mossack Fonseca clients came online today? Is the thought of the IRS knocking on your door keeping you up at night? Let me
Puerto Rico Tax Deal

The Puerto Rico tax deal is the inverse of the Foreign Earned Income Exclusion. Here’s why: With a Puerto Rico tax contract you can live in the US, your first $100,000 or so in salary is taxable, with rest deferred at 4%. If you live offshore and qualify for the FEIE, your first $101,300 is
Offshore Tax Planning Puerto Rico

You’ve heard the adage of investing when there’s blood in the streets… to buy when all hell is breaking loose and the market is at bottom. Well, now is your opportunity for some offshore tax planning while there’s blood in the streets. An offshore tax planning opportunity that will cut your corporate rate to 4%!
FBAR Due Date
08/17/2015 - 8:08 PM
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The FBAR due date has been changed from June 30 to April 15. If you file an extension for your personal return, you will have until Oct. 15 to submit your FBAR. Finally the US government has done something which makes sense. This change to the FBAR due date will help new expats big time. Here’s why:
Impact of FATCA
11/12/2014 - 12:11 PM
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Foreign Account Tax Compliance Act is finally here and you can be sure that the impact of FATCA will be severe. This brief article considers the impact of FATCA on Americans living, working, or investing overseas. FATCA is founded in a U.S. tax code that attacks small business and lavishes tax holidays on the wealthy
Foreign Pension
10/08/2014 - 10:04 AM
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If you’re working abroad for a foreign company, watch out for the foreign pension tax trap.  If you get caught, you might be paying double tax on your retirement income… once when earned by the U.S. and once at distribution in your country of residence. First, let me say that this is not meant as