News & Analysis as of

Retiring Abroad: The Lure of the Exotic, the Chore of U.S. Tax Compliance

For anyone who has watched the movie “The Best Exotic Marigold Hotel,” the idea of retiring overseas may be tempting. Glamorous locales exist around the world with warm sands, fragrant breezes and stunning sunsets where...more

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 10 of 24): IRS Issues Final Form 2015...

The IRS recently issued final instructions for Forms 1094-B and 1095-B and Forms 1094-C and 1095-C . The 2015 Instructions for Forms 1094-B and 1095-B implement a suggestion we made in a previous post relating to the...more

Successful Strategies for Doing Business in Asia: Vietnam (Updated)

WHAT ROLE WILL THE GOVERNMENT OF VIETNAM PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Ministry of Planning and Investment (MPI) is the central administrative body that oversees all investment...more

Successful Strategies for Doing Business in Asia: Thailand (Updated)

WHAT ROLE WILL THE GOVERNMENT OF THAILAND PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Thai government regulates foreign direct investment by requiring foreign investors to obtain approval from the...more

Giving Up U.S. Citizenship - Estate and Gift Tax Traps

It may be a common misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and then as a non-U.S. taxpayer make gifts or pass their estate to...more

New IRS Regs Escalate Tax Consequences of Renouncing Citizenship or Surrendering Green Card

On September 9, 2015, the IRS released long-awaited proposed regulations under Internal Revenue Code (Code) section 2801, which imposes a tax on the recipient of a gift or bequest from certain individuals who relinquished...more

Successful Strategies for Doing Business in Asia: Taiwan (Updated)

WHAT ROLE WILL THE GOVERNMENT OF TAIWAN PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? Three types of Taiwan government approval requirements may be relevant to direct foreign investment in Taiwan: •...more

Tax-Savvy Planning for Foreign Business Owners Seeking Temporary U.S. Residence: Alternatives to the EB-5 Visa

The EB-5 Visa program has been widely promoted as a legal basis for foreign business owners to gain conditional residency followed by permanent residency in the United States. The program is a great solution to the...more

International News: Focus on Private Equity

Our Focus on Private Equity provides a global perspective on some of the challenges being faced by PE firms and how these can be successfully addressed. It also examines some of the many opportunities available, e.g., by...more

Successful Strategies for Doing Business in Asia: Singapore (Updated)


Saudi Arabia update - August 2015

Legal Developments - Expatriate Workers Restricted from Certain Job Categories - As part of Saudi Arabia’s ongoing Saudization campaign, the Ministry of Labor (MoL) identified this month 19 jobs that are restricted...more

The “Reed Amendment” and Admissibility to the United States: Will I Be Barred From Reentry After Renunciation?

A common concern about renunciation of U.S. citizenship is that of admissibility to the United States thereafter. Many people tell me that they have read about a permanent ban on reentry to the United States following...more

Successful Strategies for Doing Business in Asia: Korea (Updated)

WHAT ROLE WILL THE GOVERNMENT OF KOREA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The Korean government takes an active, investor-friendly role in approving and regulating foreign direct investment....more

Successful Strategies for Doing Business in Asia: Indonesia (Updated)

1. WHAT ROLE WILL THE GOVERNMENT OF INDONESIA PLAY IN APPROVING AND REGULATING FOREIGN DIRECT INVESTMENT? The existing Indonesian Investment Act is Law No. 25 of 2007, passed by the Indonesian House of Representatives...more

Congress Continues to Threaten Contracting by Inverted Domestic Corporations - Congressional Action May Further Restrict IDCs from...

Recent congressional action regarding Inverted Domestic Corporations (IDC) may lead to further limitations on the ability of IDCs to contract with the federal government. Starting with the 2002 legislation that established...more

IRS Notice 2015-43 Addresses Expatriate Health Coverage

New guidance from the Internal Revenue Service (IRS) leaves in place the limited Affordable Care Act (ACA) exemptions set out in the Expatriate Health Coverage Clarification Act of 2014 (EHCCA). IRS Notice 2015-43 (Notice)...more

Thinking of Becoming an Expat? Watch Out for the Exit Tax

An increasing number of Americans are opting for an expatriate life. In fact, as MSN reports, more Americans than ever have renounced their U.S. citizenship in the first quarter of 2015. Moving abroad and getting a new...more

The Oman Update - The Official Gazette 1102

Sultani Decrees - Sultani Decree 20/2015 - Promulgating the GCC Common Law of Anti-dumping, Countervailing Measures & Safeguards. Sultani Decree 21/2015 - Granting Omani nationality to 288 named...more

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

Quirky Question #258, Ex Pat Trailing Partners

Question: Fred, one of our technical IT specialists, just told us that his partner volunteered for a European assignment. Fred’s a great guy and we need him but he earns less than his partner and wants the experience...more

What Expats Need to Know Now about their Taxes, FATCA and the IRS

Are you an American abroad living in perpetual fear of the IRS? Do you wake up every morning wondering if today you’ll receive a formidable notice that the taxman cometh? You are not alone. ...more

As Expatriations Increase, Potential Relief for “Accidental” U.S. Citizens

According to Treasury reports, 3,417 U.S. citizens relinquished their U.S. citizenship in 2014, which is more than the number of expatriations reported in prior years. As required by law, the Treasury publishes a quarterly...more

Quirky Question #254, Foreign currency fluctuations and expat employees

Question: I am an HR manager working for a US company that sends employees on long term assignment abroad. One of our senior assignees recently rang me to say how worried he is about Greek politics and the potential...more

Congress Clarifies the Expatriate Health Coverage Exemption

For expatriate health plans issued or renewed on or after July 1, 2015, the Expatriate Health Coverage Clarification Act of 2014 (EHCCA) provides an exemption from various Affordable Care Act (ACA) provisions. Last December,...more

Expatriate Plans Exempted from Many Affordable Care Act Provisions

In the Consolidated and Further Continuing Appropriations Act (the recently enacted federal budget bill often known as the “CRomnibus” legislation), Congress has exempted health plans designed to cover expatriates from most...more

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