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There’s also a belief that a Foreign Client who owns a US Corporation is in the same position as a US Client who owns a Domestic Corporation, which is also false. I think everyone probably knows here that an S Corporation cannot be owned by a foreign person. There’s also such an interesting form called […]
Let’s say that the Business Lawyer understands that he shouldn’t be advising on International Tax Law issues himself; let’s say that he understands that he shouldn’t be dabbling in International Tax Law. Let’s say that he understands this: the difference between US Domestic Law and US International Tax Law. Then the next question is: Did […]
The first example consists of a case I was not really involved in but I was brought in to consult on that case. But I really like it as an illustration of what happens when Business Lawyers fall into the Tax Professionals Equality Trap. In that case there was a Chinese individual who came to […]
Let me give you another example and this comes in the Voluntary Disclosure context. This time the client was a Canadian Citizen and a Permanent Resident of the United States. He received a Foreign Inheritance; and when I say a Foreign Inheritance, I mean non-Canadian and non-US. The question really was: Where should he declare […]
The Foreign Exceptionalism Trap: This is a belief that certain business transactions or events that occur completely outside of the United States do not have any US Tax Consequences for US Persons involved in these transactions. This is probably one of the most dangerous traps. One of the most common and one of the most […]