OOOOPS! Dad Gave Me A Gift from His Foreign Corporation (or Partnership)

In my practice in the Middle East I’ve found it very common that families create offshore structures (i.e., outside the USA) in various countries to hold a large […]

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Disregarded Entity – Ownership of Foreign Real Property

Part I of this blog post discussed the general concept of what is called a “disregarded entity”. It also examined how the “disregarded entity” is used (and misused) […]

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Net Investment Income Tax: 3.8% NIIT, Nit-Picky Nuances for Americans Overseas or With Offshore Investments

If you meet the requirements, your 2013 tax return will reflect the new 3.8% Medicare surcharge imposed on high wage earners. This tax is more commonly called the […]

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Transfer of Property or Cash to a Foreign Corporation? FILING OF FORM 926

Just about everyone reading this blog is aware that the IRS has made international tax enforcement a top priority and that it is attempting to flush out taxpayers […]

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