These publications do not constitute legal advise. Further information regarding this notice. Confusion at two US Consulates in Canada during recent relinquishment cases initiated by Flott & Co. clients revealed the need to develop forms and documents for use in establishing the intentional loss of US citizenship in the past. The current form, Form DS-4079,…
DetailsBy Ji Zhang, Esq., 2012/07/26 When foreign companies work through US subsidiaries to conduct business in the US, it can bring up complicated issues of who should be held responsible for the tax, and at what rate. For example, during years 2004-2007, DeCoro Limited (Parent), a Hong Kong limited liability company, manufactured furniture in China. DeCoro USA…
DetailsFLOTT & CO PC PRESENTATION ON THE US TAXATION OF INTERNATIONAL SHIPPING INCOME The Associates at Flott & Co PC, 2012/03/08 US Taxation of International Shipping Income from Flott & Co. PC Presentation on the US Taxation of International Shipping Income given to the 2nd Annual Marine Money London Ship Finance Forum by Flott & Co. PC on…
DetailsDebt obligations issued by the US government are defined as US property for estate tax purposes. Yet, what if you diversified your portfolio and have an US bank account? Would these things also count as it property within the US? It depends. Say you deposit $75,000 into ABC Bank, which is located in the US. …
DetailsThis seventh in a series of articles on the US taxation of shipping income explains the “look through” rule that applies to exemptions from the tax available pursuant to Section 883. The next article will explain what must be done to comply with the filing requirements associated with Section 883 exemptions. The tax on USSGTI…
DetailsThis is the sixth in a series of articles on the US taxation of shipping income, and continues the explanation of exemptions from the tax available pursuant to Section 883. Future articles will cover the “look through” rule and what must be done to comply with the filing requirements associated with these exemptions. The tax…
DetailsThis week, we will start with a simple issue. Say you invested in Treasury Bonds. Did you know that it property within the US for estate tax purposes, even if you are a nonresident noncitizen of the US? Debt obligations of a US person are categorized as property within the US for estate tax purposes.[1] …
DetailsIf a foreign estate owns works of art located within the US, it poses an interesting question. The Internal Revenue Code states the value of the US gross estate for a non-US citizen includes property, which at the time of his death is situated in the US.[1] Let’s say Sam, a non-US citizen, owns works…
DetailsThis is the fourth in a series of articles on the US taxation of shipping income, and explains treaty exemptions from the tax, what they are, how companies qualify and what must be done to comply with the filing requirements associated with the treaty exemption. With very few exceptions (Greece is one of the exceptions),…
DetailsSo what property has to be included on a US estate tax return? The Internal Revenue Code states the value of the estate of a foreign individual is the part of his estate situated in the US at the time of his death.[1] In 2010, foreign governments and individuals invested $1,245.7 billion, excluding derivatives, in US…
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