Series 1 – Fundamentals of International Tax

• 9/18: Introduction to International Tax – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00107-18-O)
• 10/2: Mechanisms for Offsetting U.S. Taxation of Foreign Income – Thomas Gorczynski, EA, USTCP (IRS Program Number NMVBP-T-00109-18-O)

Series 2 – Passive Foreign Investment Companies

• 10/16: PFIC Taxation Fundamentals – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00110-18-O)
• 10/23: PFIC Masterclass: Section 1291 – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00111-18-O)
• 10/30: PFIC Masterclass: QEF & MTM – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00112-18-O)

Series 3 – Advanced International Tax Issues

• 11/27: GILTI Fundamentals – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00113-18-O)
• 12/4: International Penalties and Abatement Strategies – Mary Beth Lougen, EA, USTCP (IRS Program Number NMVBP-T-00114-18-O)
  12/11: Fixing International Non-Compliance – Thomas Gorczynski, EA, USTCP (IRS Program Number NMVBP-T-00115-18-O

Join special guest instructor Mary Beth Lougen, EA, USTCP for the Compass Tax Educators webinar “Practitioner’s Guide to the Sec. 965 Repatriation Tax” on April 3, 2018. Other members of the Compass Tax Educators team will also be available on this webinar to moderate the event and answer questions.

The Tax Cuts & Jobs Act completely redefined the U.S. tax regime for foreign corporations owned by U.S. persons. To facilitate this change, Congress imposed a one-time tax on certain offshore earnings: the learning curve is steep, the IRS issued guidance only last week, and the timeline for our clients is very short. This course outlines the who, what, when, where, and, most importantly, how of computing and paying this tax.

The learning objectives for this webinar include:

• Recognize the new terminology and expanded definitions in §965.
• Identify taxpayers who are subject to the §965 repatriation tax.
• Apply IRS guidance to compute the §965 repatriation tax.
• Prepare the election to pay the §965 tax over 8 years.

We will be attending as an exhibitor the following conferences:

• October 22-23, 2017 — NYU 76th Institute on Federal Taxation – Grand Hyatt, NYC
• November 12-13, 2017  — NYU 76th Institute on Federal Taxation – Fairmont San Francisco
• November 15-17, 2017 — CalCPA Federal, State, Local and International Taxation Conference – Burbank California
• December 6-8, 2017 — ABA 34th Annual National Institute on Criminal Tax Fraud – Wynn Las Vegas

Stop by and visit Mary Beth Lougen EA USTCP at our display in the vendor’s area.
See the software in action and check out our finished product!

Upcoming trainings and presentations

PFIC related:

• Potential Issues and Benefits
• Identification, reporting, elections
• PFIC/8621 Case Study

International Taxation:

• Foreign Earned Income Exclusion & Other Things International;
• The Canadian In America

BY MARY BETH LOUGEN, EA, USTCP

Practitioners that work with clients who have international connections often have to run the gauntlet of Code Secs. 1291–1298, the portion of the statute that covers passive foreign investment companies or PFICs. As someone who frequents the PFIC regulations, I am always in awe of this section of the Internal Revenue Code (“the Code”). The men and women who took the directive provided by Congress in the Tax Reform Act of 1986 and put to paper how we are to treat passive foreign investment companies on a U.S. tax return were geniuses. They have woven an intricate and complex web of “if this, then that” rules that speak to many other sections of the Code—if the PFIC is also a CFC, then … , if the shareholder becomes a U.S. person after already owning an investment that became a PFIC the minute they crossed into U.S. personhood, then … , if the investment was owned prior to 1987 when the regulations came into play, then … . But there is one place where the interaction between the PFIC rules and the rest of the regulations is not in sync, this is the case when there is a sale of a fiscal year qualified electing fund (QEF) during the period between the end of the fiscal reporting year and the taxpayer’s calendar year end.

It is widely thought that QEF election is the best solution to a bad problem— but I am going to have to disagree, or at least disagree when the PFIC reports on a fiscal year.

Read the full article.

Download the article in PDF format.

Attending CalCPA‘s conference this week?

Come listen to our own Beth Lougen tomorrow at her workshop: Understanding Form 8621 in Room A at 3:05 pm. Or drop by the Expat Tax Tools booth for a free demo.

Press Release

Mary Beth Lougen of Expat Tax Tools to speak at USD School of Law – PITI Conference

SAN DIEGO, October 5, 2016 /PRNewswire/ — Expat Tax Tools is proud to announce that COO Mary Beth Lougen has been asked to speak at the The University of San Diego School of Law – Procopio International Tax Institute international tax conference, held on October 20-21 at the Joan B. Kroc Institute for Peace and Justice in San Diego. Mary Beth states that this is a very prestigious event and she is honored to be asked to be a part. Mary Beth’s topic for discussion is “Taxation Dilemmas of International Retirement Plans”.

Wednesday, December 16, 2015
1:00 PM to 2:00 PM ET

DESCRIPTION

This program goes back to basics to reinforce how the current tax code affects the personal income tax situations for your employees on foreign assignment.  A well-crafted package can allow your employee to benefit from the best the Internal Revenue Code and State Tax Codes have to offer on a personal level.  Too often, employees on international assignments are surprised at tax time to learn that they do not qualify for federal earned income exclusions or state safe harbor programs which could have saved them thousands in taxes.  When employees accept assignments outside the United States and are provided with a thoughtful employment package that considers not only the company’s interest but their own, your company will be able to retain talent easier and have employees more willing to accept international assignments.

More Information

BY MARY BETH LOUGEN, EA, USTCP

If the federal treatment of passive foreign investment companies (PFICs) under I.R.C. §§1291–1298 isn’t enough to send you screaming from the room, have you ever considered how the various states view that same investment?

Once you start looking closely at the multiple federal treatments and how many ways a state can view those treatments, you quickly realize that the number of considerations and potential issues awaiting your clients is on a scale that is so large it can overwhelm the most seasoned professional. This article will bring up more questions than it answers and is intended to have you really think about what you are dealing with when you have a client with a U.S. state residency or domicile who also owns a PFIC.

You need to stop and thoughtfully evaluate how the state will treat income that is included in federal AGI but does not meet the definition for constructive receipt, income that is constructively received but not included in federal income, losses that are taxed differently than gains for the same investment, losses that are accounted for in different years than gains, income not included in AGI but instead subject to an additional tax by the IRS and just as many
variations of basis adjustments.

As I see it, the main issues are:

• determining when state adjustments are required to accurately reflect state income,
• how to recognize when state and federal basis may be different due to timing of income inclusions, and
• lack of guidance by many state tax codes…

Read the full article.

Download the article in PDF format.

For those of U.S. who work in the arena of international taxation our idea of a great client is one who lives in Texas, Washington or any of the sevens states that do not impose income tax on their residents. On a good day figuring out how to prepare the federal tax returns for people whose fiscal lives cross international borders can be vexing and time consuming. But throw an extra taxing jurisdiction into the mix and there are now another set of regulations to consider. What may have been the best outcome when considering only the implications at the federal level may no longer be the case…