Understanding The 'Pick And Choose' Issue In The US-Japan Income Tax Treaty
Navigating the intricacies of the US-Japan Income Tax Treaty can be challenging, especially when it comes to the 'pick and choose' issue. This...
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Learn about Cross Border Tax
We regularly updates our blogs to provide latest insights in international taxation.
$USGermanyIncomeTaxTreaty
U.S.-Germany Tax Treaty Unveiled: Optimizing Taxes for Dual Residents
Straddling two tax systems? Learn how the U.S.-Germany Tax Treaty helps dual residents reduce double taxation and keep more of their income.
Koh Fujimoto
Jun 9, 2025
#PassiveForeignInvestmentCompanies
PFIC Reporting for U.S. Investors with Foreign Mutual Funds: Tax Strategies & Compliance Guide
Don’t let PFIC rules catch you off guard. Get the facts, filing tips, and strategies to protect your investments and your wallet.
Koh Fujimoto
May 31, 2025
#AFR
Understanding the Applicable Federal Rate in International Loans
A loan can be an effective tool to finance your international transaction. Navigating the complexities of international loans requires a deep...
Koh Fujimoto
May 29, 2025
Understanding Japanese Inheritance Mediation Processes
Navigating the complexities of inheritance mediation in Japan can be challenging. This blog post aims to demystify the process, providing clear...
Koh Fujimoto
May 28, 2025
#foreigntaxcredit
Filing Form 1116: Maximizing Your Foreign Tax Credit
Master the complexities of Form 1116 to make the most of your foreign tax credit and minimize your tax liability.
Koh Fujimoto
May 10, 2025
#ftc
Retirement Tax Strategies for US Citizens Moving to Southeast Asia
Retiring in Southeast Asia? Don't let taxes spoil your dream! Discover smart strategies for US expats in Thailand, Philippines, Vietnam & Malaysia.
Koh Fujimoto
Apr 21, 2025
#FBAR
Step by Step Guide for FBAR Filing: Complete 2025 Instructions
Learn the step-by-step process for filing your 2025 Foreign Bank Account Report (FBAR) accurately and on time. Understand who needs to file, what...
Koh Fujimoto
Apr 8, 2025
#FBAR
Step-by-step Guide About Setting Up Cross-border Lifestyle. Your Taxes, Residence, Social Security Taxes, Gift Taxes And Living Trust For Americans
As an American, unlock the secrets to navigating the complexities of a cross-border lifestyle and ensure your financial and legal matters are in...
Koh Fujimoto
Apr 5, 2025
#PassiveForeignInvestmentCompanies
Do You Have to Report Your Foreign Investment, such as Index Funds in your Home Country, to the IRS under PFIC Rules?
Navigating the complexities of international investments can be daunting, especially when it comes to understanding Passive Foreign Investment...
Koh Fujimoto
Mar 30, 2025
#foreigntaxcredit
How to Claim Foreign Tax Credits for Japanese Taxes Paid While You Are Living in Japan
Navigating the complexities of foreign tax credits can be challenging, but understanding the process can save you from paying double taxes. Learn how...
Koh Fujimoto
Mar 23, 2025
#foreignpension
Form 3520 Reporting Exceptions: What Are Applicable Tax-Favored Foreign Trusts?
Understanding the exemptions under Form 3520 can save you from unnecessary reporting hassles. Learn about Applicable Tax-Favored Foreign Trusts.
Koh Fujimoto
Mar 20, 2025
#PassiveForeignInvestmentCompanies
Key Exceptions in PFIC Reporting You Should Know
Navigating the complexities of Passive Foreign Investment Company (PFIC) reporting can be daunting, but understanding key exceptions can save you...
Koh Fujimoto
Mar 5, 2025
#usestatetax
Estate Tax Rules for Non-US Citizen Spouses
Navigating the intricate landscape of estate tax rules can be especially challenging for non-US citizen spouses, who face unique legal hurdles and...
Koh Fujimoto
Feb 16, 2025
#usestatetax
Estate Tax Rules for Non-Residents in the US -Assets in the US
Navigating the complexities of estate tax rules for non-residents with assets in the US can be challenging, but understanding these regulations is...
Koh Fujimoto
Feb 13, 2025
#like-kindexchange
Section 1031 Exchanges-a Foreign Property?
Can you exchange your foreign real estate property with a US real property under Section 1031, Like-kind exchange? I'd like you to understand the...
Koh Fujimoto
Feb 8, 2025
American Citizen Death Abroad: Why Foreign Death Certificates May Not be Good for US Estates
When a US citizen passes away abroad, settling their estate back home can become a complex and frustrating process.
Koh Fujimoto
Jan 26, 2025
#FBAR
Failure to File Form 8833 does not Waive the Benefits of the Tie-Breaker Rule of Tax Treaty
Form 8833 is critical and needs prompt filing. However, this court still granted the plaintiff the benefits of the tax treaty, making the taxpayer a...
Koh Fujimoto
Jan 9, 2025
#FBAR
U.S. V. Saydam: Significance Of Willfulness Definition
The U.S. v. Saydam case has brought to light the critical nuances of the legal definition of 'willfulness,' which could have far-reaching...
Koh Fujimoto
Jan 1, 2025
#lastdaygreencard
Your Last Day as a Green Card Holder -US Regulations
Navigating the complexities of abandoning your green card can be overwhelming. Understanding the regulations can make the process smoother.
Koh Fujimoto
Dec 29, 2024
#foreigninheritance
Navigating Taxes on Gifts from Covered Expatriates
Understanding the tax implications of gifts from covered expatriates is crucial for US persons to avoid unexpected liabilities.
Koh Fujimoto
Dec 27, 2024
#exittax
US Exit Tax: Mastering Net Asset Value Calculation: A Complete Guide
Understanding how to calculate your net asset value when considering US exit tax can save you from unexpected financial pitfalls.
Koh Fujimoto
Dec 25, 2024
#abandoninggreencard
"Is 10-year period rule still applicable?" Navigating US Tax Expatriation Rules: Sections 877 and 877A
Understanding the complexities of US tax expatriation rules is crucial for anyone considering giving up their US citizenship or long-term residency.
Koh Fujimoto
Dec 24, 2024
#exittax
What is exactly "net income tax" in Form 8854 (average net income tax liability test)?
Understanding 'net income tax' in Form 8854 is crucial for expatriates to navigate the average net income tax liability test effectively.
Koh Fujimoto
Dec 24, 2024
#exittax
No Early Withdrawal Penalty-401k Withdrawals under Exit Tax rules: What You Need to Know
Discover how you can withdraw from your 401k without penalties under Exit Tax rules, and what this means for your financial future.
Koh Fujimoto
Dec 23, 2024
#CFC
PFIC vs CFC: Key Differences and Tax Implications
Understanding the intricacies of PFIC and CFC rules can be crucial for investors and businesses dealing with foreign investments.
Koh Fujimoto
Dec 21, 2024
#SusbstantialPesenceTestException
A Comprehensive Guide to the IRS Substantial Presence Test
Navigating the complexities of the IRS Substantial Presence Test can be daunting, but understanding it is crucial for anyone looking to establish...
Koh Fujimoto
Dec 21, 2024
What is Inside and Outside basis of US partnership?
Demystify the complexities of partnership taxation by understanding the nuances between inside and outside basis calculations, especially when debt...
Koh Fujimoto
Nov 29, 2024
#USgifttax
Calculating US Capital Gains on Gifted Property Made Simple
Navigating the complexities of capital gains on gifted property doesn't have to be daunting. Here's a simplified guide to help you understand the...
Koh Fujimoto
Nov 28, 2024
#dividendreceiveddeduction
How US Corporations Can Benefit from Section 245A
Unlocking Tax Efficiency: The Hidden Benefits of Section 245A for US Parent Corporations
Koh Fujimoto
Nov 23, 2024
#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.
Koh Fujimoto
Nov 21, 2024
#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
Watch out for loans from your CFC- Indirect Repatriation (US investments) of CFC Earnings: What You Need to Know
Navigating the complexities of Controlled Foreign Corporations (CFCs) can be daunting, especially when it comes to indirect repatriation of earnings....
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 the complexities of income tax as an F-1 student can be daunting, but understanding the source rules can help you stay compliant and avoid...
Koh Fujimoto
Oct 30, 2024
#CFC
US Tax Laws: Key Points for Controlled Foreign Corporations for Cross-Border Individuals
Navigating the complex maze of US tax laws can be daunting, especially when dealing with Controlled Foreign Corporations. Discover the key points you...
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 Members
Understanding the nuances of constructive ownership of stock can be pivotal for investors and business owners alike. Learn how family members factor...
Koh Fujimoto
Oct 12, 2024
#foreigntaxcredit
USE IT or LOSE IT-US Foreign Tax Credit Carry Forward
Navigating the complexities of foreign tax credits can be daunting, especially when dealing with the implications of abandoning a green card. Learn...
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 Calculation compared to Foreign Tax Deduction
Navigating the complexities of US Foreign Tax Credit and Foreign Tax Deduction can significantly impact your tax bill. Discover the key differences...
Koh Fujimoto
Sep 25, 2024
#importedlossproperty
Navigating Built-In Loss Limitations for Non-US Investors in US corporate formation
Unlocking the potential of US corporate investments while understanding the tax intricacies is vital for non-US investors. Learn how to navigate...
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
Navigating the complex tax implications of contributing appreciated property to a foreign partnership can be daunting, but understanding these...
Koh Fujimoto
Sep 17, 2024
Under The US Tax Laws, The Source Of Interest Income Is Generally Controlled By The Residence Or The Place Of Incorporation Of The Obligor
Navigating the complexities of US tax laws can reveal significant advantages by allocating more income to foreign sources.
Koh Fujimoto
Sep 11, 2024
＃USpartnershiptax
Understanding IRS Guidelines for 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
Must Know Tax Knowledge: 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
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