#checkthebox
Mastering Check-the-Box Election Rules for Your Business in the US
Unlock the potential of your US business with a strategic understanding of check-the-box election rules.
Blog
Learn about Cross Border Tax
We regularly updates our blogs to provide latest insights in international taxation.
#Permanent Establishment
Understanding US trade or business and permanent establishment
Unlock the complexities of US trade and permanent establishment definitions to optimize your international business strategies.
Koh Fujimoto
Nov 21, 2024
#PassiveForeignInvestmentCompanies
Navigate PFIC tax by Taking Advantage of Elections
Unlocking the potential to minimize tax burdens on your PFIC investments through strategic elections.
Koh Fujimoto
Nov 7, 2024
#GILTI
Loans from your CFC- Indirect Repatriation (US investments) of CFC
Navigating Controlled Foreign Corporation (CFC) complexities can be daunting with indirect earnings repatriation. Learn to avoid Section 956...
Koh Fujimoto
Nov 2, 2024
#GILTI
GILTI Mechanism. How To Calculate Your GILTI Tax
Navigating the complexities of GILTI tax calculations can be daunting, but understanding the mechanism is crucial for optimizing your tax strategy.
Koh Fujimoto
Nov 2, 2024
Understanding Source Rules for F-1 Student Income
Navigating income tax complexities as an F-1 student can be daunting, but understanding source rules helps you stay compliant and avoid penalties.
Koh Fujimoto
Oct 30, 2024
#CFC
US Tax Laws: CFC Key Points for Cross-Border Individuals & Families
Navigating complex US tax laws can be daunting when dealing with Controlled Foreign Corporations. Discover key points to stay compliant and optimize...
Koh Fujimoto
Oct 17, 2024
#CFC
CFC Designation And Foreign Person Stock Ownership Section 958(b)
Understanding how nonresident aliens impact CFC designation can save businesses from unexpected tax liabilities.
Koh Fujimoto
Oct 13, 2024
#attributionrule
Constructive Ownership of Stock: What You Need to Know About Family
Understanding constructive ownership of stock nuances is pivotal for investors and business owners. Learn how family members factor into this tax law.
Koh Fujimoto
Oct 12, 2024
#foreigntaxcredit
USE IT or LOSE IT-US Foreign Tax Credit Carry Forward
Navigating foreign tax credit complexities can be daunting when abandoning a green card. Learn to maximize unused FTCs before they expire.
Koh Fujimoto
Oct 10, 2024
#foreigntaxcredit
Watch Out the Foreign Tax Credit Limitations
Mastering the intricacies of the foreign tax credit limitation formula can significantly reduce your tax burden and optimize your financial strategy.
Koh Fujimoto
Oct 4, 2024
#Recourseliabiltiy
Determining a Partner's Basis in a Partnership with Recourse Liability
Understanding how recourse liabilities affect a partner's basis in a partnership is crucial for accurate tax reporting and financial planning.
Koh Fujimoto
Sep 27, 2024
#83(b)
83(b) Advantages and disadvantages of Election
Let's take a closer look at the tax benefits and risks of choosing 83(b) Election.
Koh Fujimoto
Sep 26, 2024
#foreigntaxcredit
Understanding US Foreign Tax Credit and Foreign Tax Deduction
Navigating US Foreign Tax Credit and Deduction complexities can significantly impact your tax bill. Discover key differences and which option...
Koh Fujimoto
Sep 25, 2024
#importedlossproperty
Built-In Loss Limitations for Non-US Investors in US Corp Formation
Unlocking US corporate investment potential while understanding tax intricacies is vital for non-US investors. Learn to navigate built-in loss...
Koh Fujimoto
Sep 24, 2024
#dividendreceiveddeduction
Understand Dividends Received Deduction -245A
Unlock the secrets of the Dividends Received Deduction under Section 245A to maximize your tax benefits.
Koh Fujimoto
Sep 18, 2024
#partnershiptax
Cross-Border Partnership: Tax Guidelines for Appreciated Property
Navigate complex tax implications of contributing appreciated property to foreign partnerships. Understanding is crucial for compliance.
Koh Fujimoto
Sep 17, 2024
The Source Of Interest Income Rule: Interest Income
Navigating the complexities of US tax laws can reveal significant advantages by allocating more income to foreign sources.
Koh Fujimoto
Sep 11, 2024
＃USpartnershiptax
Nonrecognition of Gain or Loss on Contribution to a Partnership
Explore the pivotal IRS Section 721(a) and how it influences your tax responsibilities when contributing property to a partnership.
Koh Fujimoto
Sep 10, 2024
#usestatetax
Step Up Basis: A Key Factor in Estate Tax Planning
Discover how the step-up basis can significantly reduce estate taxes and ensure a smooth financial transition for heirs.
Koh Fujimoto
Sep 6, 2024
#foreignappreciatedpropertycontribution
Be Aware! Your Contribution to US Partnership May Trigger US Tax
Explore the complex landscape of tax implications when foreign partners contribute property to U.S. partnerships.
Koh Fujimoto
Sep 6, 2024
#transferatdeath
Understanding Capital Gains Tax on Inherited Property
Navigating capital gains tax on inherited property can be daunting, but understanding its nuances can lead to significant financial benefits.
Koh Fujimoto
Sep 6, 2024
#entityclassification
Critical Foreign Entity Classification for US Tax
Navigating the complexities of foreign entity classification for US tax purposes can be daunting but crucial for compliance and optimization.
Koh Fujimoto
Sep 4, 2024
#crossbordertax
US Gift Tax Secret: Are Gifts from Non-US Citizens Taxable in US ?
Navigating the complexities of receiving gifts from abroad can be perplexing. Discover whether gifts from non-US citizens are subject to U.S. taxes.
Koh Fujimoto
Sep 4, 2024
#USgifttax
Form 709 Instructions: Complete Guide for Cross-Border Individuals
Navigating cross-border gifting complexities can be challenging. Discover essential insights for filling out US Form 709 with step-by-step guidance.
Koh Fujimoto
Aug 18, 2024
#USgifttax
Domicile & Residency for Cross-Border Individuals: US Tax Perspective
Must read for cross-border gifting and inheritance planning. Explore how domicile and residency impact US gift and estate taxes for cross-border...
Koh Fujimoto
Aug 18, 2024
#gifttaxlifetimeexclusion
US Gift Tax Filing Requirements for Cross Border Individuals
Avoid costly mistakes! Navigate complex US gift tax regulations for cross-border individuals. Understanding these requirements is crucial.
Koh Fujimoto
Aug 18, 2024
#streamlinedprocedures
No Penalty! Use Streamlined Offshore Procedures - Cross-Border Users
Discover how streamlined offshore foreign reporting procedures simplify tax compliance and bring peace of mind to cross-border individuals and...
Koh Fujimoto
Aug 18, 2024
#gifttaxlifetimeexclusion
US Lifetime Gift Tax Exemption & Domicile for Cross-Border Families
Explore how US domicile status influences the $13.6 million lifetime gift tax exemption for cross-border families, ensuring tax savings and...
Koh Fujimoto
Aug 17, 2024
#foreigngifts
How to Report Foreign Gifts on IRS Tax Forms
Navigating international gift reporting complexities can save you from unexpected tax complications. Learn to properly report foreign gifts to the...
Koh Fujimoto
Aug 15, 2024
#streamlinedprocedures
SDOP- "5% of the Year-End Balance"
Navigate offshore tax compliance complexities. Learn how to accurately compute Streamlined Domestic Offshore penalty for peace of mind.
Koh Fujimoto
Aug 15, 2024
#streamlinedprocedures
Avoiding Pitfalls in Streamlined Filing Compliance
Navigating streamlined filing compliance complexities can be daunting. Learn to sidestep common mistakes and ensure nonwillful, accurate, timely...
Koh Fujimoto
Aug 14, 2024
#FBAR
FBAR Penalties: Willful vs Non-Willful for Cross Border Individuals
Explore critical distinctions between willful and non-willful FBAR penalties and their implications for individuals with cross-border financial...
Koh Fujimoto
Aug 12, 2024
#FBAR
Understanding Criminal Charges for FBAR Neglect
Explore serious implications of failing to file Foreign Bank and Financial Accounts Report (FBAR), critical for U.S. taxpayers with foreign interests.
Koh Fujimoto
Aug 12, 2024
#FBAR
FBAR Filing: Life Insurance Cash Value Requirements
Unveil the complexities of FBAR filing for life insurance policies with significant cash values.
Koh Fujimoto
Aug 12, 2024
#FBAR
Cross Border FBAR Essentials: Handling Foreign Pension Accounts
Navigate the complexities of FBAR compliance for your foreign pension accounts with expert guidance.
Koh Fujimoto
Aug 12, 2024
#FATCA
Avoiding FATCA Penalties: Tips for Cross-Border Individuals & Families
Navigating Foreign Account Tax Compliance Act (FATCA) complexities can be daunting for expatriates. Essential tips to help cross-border families...
Koh Fujimoto
Aug 11, 2024
#FBAR
Late FBAR Filing: Strategies for Compliance Cross Border Individuals
Navigate the complexities of late FBAR filings with expert strategies designed for cross border individuals.
Koh Fujimoto
Aug 8, 2024
#FBAR
Are You Required to File FBAR?
Navigating FBAR complexities can be daunting for cross-border individuals. Find out if you must file, understand the process, and avoid penalties.
Koh Fujimoto
Aug 7, 2024
#dualcitizen
How Dual Citizenship Reshapes Cross-Border Tax Issues: US & Japan
Explore the transformative potential of dual citizenship on tax obligations for individuals navigating between the US and Japan.
Koh Fujimoto
Aug 4, 2024
#dualcitizen
Future Prediction and Possibility of Dual U.S.-Japan Citizenship
We will explore the legal and social challenges faced by dual U.S.-Japan citizens and their future prospects.
Koh Fujimoto
Aug 1, 2024
#duallocationliving
Dual Citizenship Tax Guide
Navigate the complex world of taxes with our comprehensive guide on dual citizenship tax implications.
Koh Fujimoto
Jul 31, 2024
#abandoninggreencard
US Tax Duties After Renouncing Permanent Residency
Discover the pivotal tax responsibilities that linger after you renounce your U.S. permanent residency.
Koh Fujimoto
Jul 24, 2024
#abandoninggreencard
How To Submit I-407
Discover the essential steps to relinquish your Green Card smoothly with Form I-407.
Koh Fujimoto
Jul 23, 2024
#abandoninggreencard
Planning For Giving Up Your Greencard
Discover the essential steps and legal implications of relinquishing your U.S. green card, including tax responsibilities and exit tax considerations.
Koh Fujimoto
Jul 23, 2024
#abandoninggreencard
Abandoning Green Card Status Process
Discover the essential steps and considerations for legally relinquishing your U.S. permanent residency.
Koh Fujimoto
Jul 18, 2024
#bicoastallifestyle
Optimizing US-Japan Income Tax to Avoid Double Taxation
Discover strategic insights and practical advice for US and Japan residents to manage and reduce the burden of double taxation on their income.
Koh Fujimoto
Jul 17, 2024
#foreignpartnersinusllc
US LLC Taxation Simplified for Non-Resident Investors
Navigating tax landscape as a non-resident US LLC investor can be complex. This blog simplifies taxation and provides valuable foreign investor...
Koh Fujimoto
Jul 10, 2024
#taxtreaty
Resolving Inconsistencies US Tax Treaty and US Federal Tax Law
Navigate the complex landscape of US tax treaties and federal tax law to effectively resolve conflicts and optimize your tax strategy.
Koh Fujimoto
Jul 9, 2024
#eligibledeferredcompensation
Smart Strategies to Lower Your Exit Tax Burden
Navigate the complexities of exit taxes with strategies to reduce your financial impact.
Koh Fujimoto
Jul 5, 2024
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