Podcasts about pfic

Are your foreign investments quietly wrecking your US tax situation? They might be. This week's Ask An Expert show features Brian Dunhill, a seasoned financial planner based in the UK, to tackle one of the trickiest topics in expat finance: PFICs (Passive Foreign Investment Companies). Host and founder of Plan First Wealth, Richard Taylor, and founder of Dunhill financial Brian walk you through: What PFICs are and why they're a major tax trap for US citizens and expats.How IRS rules make foreign investing more complicated, and costly.Ways to avoid harsh penalties, including using the Streamlined Filing Compliance Procedures.Smart investment strategies that steer clear of PFIC issues while still diversifying internationally.How the DF Direct platform lets you invest in non-U.S. currencies without triggering PFIC rules.Brian shares real-life stories of expats who've navigated PFIC trouble - and how they got out of it. Brian is the founder of Dunhill Financial, a firm that specialises in cross-border financial planning and wealth management. The firm is based in London and focuses on assisting Americans living abroad and expatriates in the United States.Brian and his firm are adept at handling financial advisory needs that cross national borders, particularly involving US and European regulations.We're the Brits in America is affiliated with Plan First Wealth LLC, an SEC registered investment advisor. The views and opinions expressed in this program are those of the speakers and do not necessarily reflect the views or positions of Plan First Wealth. Information presented is for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and unless otherwise stated, are not guaranteed. Be sure to first consult with a qualified financial adviser and/or tax professional before implementing any strategy discussed herein. Plan First Wealth does not provide any tax and/or legal advice and strongly recommends that listeners seek their own advice in these areas.

Ever wondered what really happens when a U.S. citizen inherits assets from their Canadian parents?Spoiler: it's not as simple as you'd think.In today's episode, host Gerry Scott sits down with Aaron Dawes, cross-border tax expert from Smythe LLP, to unpack the increasingly common—but often misunderstood—scenario of U.S. individuals inheriting Canadian assets. With more families living cross-border lifestyles and adult children relocating south, questions around tax, compliance, and estate planning have taken on a whole new level of complexity.Aaron breaks down what Americans need to know when it comes to Canadian inheritances—covering everything from brokerage accounts and real estate to RRSPs and even mutual funds (hello, PFIC reporting!). He also shares important guidance for Canadian parents who want to ensure their U.S.-based children don't end up tangled in unnecessary tax trouble.Plus, they touch on the rise of dual-country living, why California residents often get the short end of the treaty stick, and what both sides of the border can do to minimize the risk of double taxation.Whether you're the beneficiary, the planner, or somewhere in between, this episode will give you a better understanding of the tax landscape and how to protect your assets—and your sanity.Key Takeaways:What U.S. beneficiaries need to report when inheriting Canadian assetsWhy Canadian mutual funds can trigger complicated (and costly) U.S. tax filingsHow the Canada–U.S. tax treaty works—and when it doesn'tThe role of executors and why residency mattersSteps Canadian parents can take now to ease the future burden on their U.S. childrenAbout the Guest:Aaron Dawes, CPA, is a partner at Smythe LLP, a British Columbia-based accounting firm with offices in Vancouver, Langley, and Nanaimo. Specializing in U.S.-Canada cross-border taxation, Aaron works closely with families and business owners navigating complex estate, income, and compliance matters across borders.Next Episode Teaser:Stay tuned for part two, where we flip the script: What Canadian beneficiaries need to know when inheriting from U.S. parents—especially when irrevocable trusts come into play.

An accountant moves to the US in the 1980s with a portfolio of non-U.S. mutual funds (classified as PFICs under US tax law). Decades later and the portfolio has grown significantly, but is never reported under the US PFIC rules. Assuming it was taxed like a standard investment, the accountant has blindly walked into an 80% penalty, lost to taxes and interest. This cautionary tale highlights the critical need for early, specialised cross-border tax advice. Thankfully, we've got it here. Richard Taylor is joined for this week's Ask An Expert by Ishali Patel, Senior Director at Trowbridge Professional CorporationThey explore key issues like informational returns (FBAR, Form 3520), the PFIC regime for non-U.S. investments, and double-taxation risks when working across states. If you do a couple of days work a week in another state you could be taxed twice! It's bonkers, but need-to-know stuff. Ishali also shares insights on avoiding costly penalties and managing UK pensions under US rules.We're the Brits in America is affiliated with Plan First Wealth LLC, an SEC registered investment advisor. The views and opinions expressed in this program are those of the speakers and do not necessarily reflect the views or positions of Plan First Wealth. Information presented is for educational purposes only and does not intend to make an offer or solicitation for the sale or purchase of any specific securities, investments, or investment strategies. Investments involve risk and unless otherwise stated, are not guaranteed. Be sure to first consult with a qualified financial adviser and/or tax professional before implementing any strategy discussed herein. Plan First Wealth does not provide any tax and/or legal advice and strongly recommends that listeners seek their own advice in these areas.

Gain expert insights into best practices in diagnosing progressive familial intrahepatic cholestasis (PFIC), Alagille syndrome, and biliary atresia. Credit available for this activity expires: 11/25/25 Earn Credit / Learning Objectives & Disclosures: https://www.medscape.org/viewarticle/1001956?ecd=bdc_podcast_libsyn_mscpedu

Please visit nascentmc.com/podcast for all the details.  Go to learnAMAstyle.com for lots of freebies on AMA Style and the use of AI in medical writing and editing Here is information on the latest US FDA approvals, the week of March 11 – March 15, 2024 Liso-cel for CLL/SLL   - The FDA approved lisocabtagene maraleucel (liso-cel; Breyanzi) for adult patients with relapsed or refractory chronic lymphocytic leukemia (CLL) or small lymphocytic lymphoma (SLL) who have received at least two prior therapies. It is a CAR T-cell therapy that modifies patient's T cells to target tumor antigens. The approval was based on the TRANSCEND CLL 004 study, showing a 20% complete response rate and a median duration of response not reached by the data cutoff. Tislelizumab for Esophageal SCC   - Tislelizumab-jsgr (Tevimbra) received FDA approval for unresectable or metastatic esophageal squamous cell carcinoma (ESCC) patients after prior systemic chemotherapy. The approval was based on the phase 3 RATIONALE 302 trial, which showed significant improvement in overall survival compared to chemotherapy (8.6 months vs. 6.3 months). This marks a critical advancement for patients with limited treatment options after first-line failures. Resmetirom for NASH   - The FDA approved resmetirom (Rezdiffra) for adults with non-cirrhotic non-alcoholic steatohepatitis (NASH) with moderate to advanced fibrosis, to be used alongside diet and exercise. This is the first medication approved to directly address liver damage in NASH patients with significant liver scarring, acting as a partial activator of a thyroid hormone receptor to reduce liver fat. The approval, based on a 54-month trial, used a surrogate endpoint at 12 months to demonstrate improvement in liver scarring and inflammation. Maralixibat for Cholestatic Pruritus   - Maralixibat (Livmarli) oral solution was approved for treating cholestatic pruritus in patients aged 5 years and older with progressive familial intrahepatic cholestasis (PFIC). It is an orally administered ileal bile acid transporter inhibitor, showing efficacy in the Phase 3 MARCH clinical trial across various genetic types of PFIC. Additionally, a higher concentration formulation is under consideration to extend its use to younger PFIC patients. Guselkumab for UC   - A supplemental Biologics License Application (sBLA) has been submitted for guselkumab (Tremfya) for treating adults with moderate-to-severely active ulcerative colitis (UC). The submission is based on the QUASAR program results, demonstrating significant clinical remission at Week 44 compared to placebo. Guselkumab, a novel IL-23 inhibitor, has previously been approved for moderate-to-severe plaque psoriasis and active psoriatic arthritis, marking its potential expansion into UC treatment.  

Listen in as we discuss intricacies of FBAR (Report of Foreign Bank and Financial Accounts), Form 8938 (Statement of Specified Foreign Financial Assets), and PFIC (Passive Foreign Investment Company) reporting requirements.Navigating the complexities of international tax compliance can be challenging, especially when it comes to reporting foreign financial assets and investments. Whether you are an individual taxpayer, a tax professional, or a financial advisor, understanding these reporting obligations is crucial to ensure compliance with the IRS regulations and avoid potential penalties.CPAs Varshika Gupta and Rajesh Ghimire, along with our Client Services Manager, Arianna Gonzalez, MBA, covered an overview of FBAR, Form 8938, and PFIC reporting requirements; reporting thresholds and filing deadlines; strategies for managing PFIC investments and minimizing tax implications; and many more. Listen In!

In der heutigen Folge geht es um Diagnostik und Therapien für intrahepatische Cholestasesyndrom. Frau Professor Keitel erklärt das rationelle diagnostische Vorgehen bei Transporterdefekten, von ABCB4 Varianten bei Patienten mit LPAC-Syndromen und PFIC-3 bis zu den anderen PFIC-Typen (normale gGT bei PFIC-1 und PFIC-2). Im zweiten Teil werden die Indikation für den Einsatz der neuen IBAT-Inhibitoren und die klinische Effektivität diskutiert.

This lecture was given on May 2nd, 2023, at the University of Washington. For more information on upcoming events, please visit our website: https://thomisticinstitute.org/upcoming-events Speaker Bio: Fr. Jordan Schmidt was born in Fargo, ND, and attended St. John's University in Collegeville, MN for his undergraduate studies. After entering the Order of Preachers, he came to Washington DC to study theology, graduating from the PFIC in 2009 with an STB/MDiv in theology and from CUA in 2012 with an STL in biblical theology. Upon his ordination to the priesthood, he was appointed associate pastor of St Mary's parish in New Haven, CT where he served until 2013. Fr. Jordan next returned to the Dominican House of Studies in Washington, DC to pursue doctoral studies at CUA. Since earning his Ph.D. in Biblical Studies in 2018, he has been teaching various courses in Sacred Scripture at the PFIC.

Establishing insurance-linked securities (ILS) investment management operations and the impact of recent international tax developments in the industry was the focus of our latest Artemis Live video interview.  Our latest Artemis Live podcast episode is with Scott Slater of PwC, a Partner and the Tax Services Leader at PwC Bermuda. Scott also leads PwC in the Caribbean's International Tax Services group, which is based in Bermuda and the Cayman Islands. In this interview we discussed some recent international tax developments and how they could affect insurance, reinsurance and also insurance-linked securities (ILS) interests. Slater explained that a key area of focus for his practice and team, in relation to insurance-linked securities (ILS) market participants, is the controlled foreign corporation (CFC) rules and the passive foreign investment company (PFIC) rules. “In the ILS space, most of these structures are either CFC's or PFIC, and our practice specialises in giving the information that those US investors need to complete their tax returns and satisfy their reporting requirements for making that foreign investment,” he said. Slater also explained that a component of the work his team at PwC undertakes is to help ILS investment managers identify the right structures for their businesses, from a taxation point of view. “It's an interesting conversation, particularly with those asset manager backed ILS vehicles, to explain to them what has to happen in Bermuda and the people they need to get in Bermuda to satisfy those requirements, to mitigate the risk that they've somehow created a taxable presence in the US. “So we work with a lot of clients around the structure, but also the people functions and the activities that need to happen from Bermuda, to achieve that tax result,” he commented.  Listen to this podcast episode for more insights from PwC Bermuda's Scott Slater.

Gordon Dale has over 14 years of experience with the Big 4 accounting firms and a top 15 Regional accounting firm and he's here to tell us everything we need to know about Passive Foreign Investment Company (PFIC).

This lecture was given on December 3, 2022, at the Thomistic Institute's West Coast Intellectual Retreat entitled, "The Eschaton: An Intellectual Retreat on the End of the World." For more information on upcoming events, please visit our website at www.thomisticinstitute.org. About the speaker: Fr. Jordan Schmidt was born in Fargo, ND, and attended St. John's University in Collegeville, MN for his undergraduate studies. After entering the Order of Preachers, he came to Washington DC to study theology, graduating from the PFIC in 2009 with an STB/MDiv in theology, and from CUA in 2012 with an STL in biblical theology. Upon his ordination to the priesthood, he was appointed associate pastor of St Mary's parish in New Haven, CT where he served until 2013. Fr. Jordan next returned to the Dominican House of Studies in Washington, DC to pursue doctoral studies at CUA. Since earning his PhD in biblical studies in 2018, he has been teaching various courses in Sacred Scripture at the Pontifical Faculty of the Immaculate Conception at the Dominican House of Studies.

This lecture was given on December 2, 2022, at the Thomistic Institute's West Coast Intellectual Retreat entitled, "The Eschaton: An Intellectual Retreat on the End of the World." For more information on upcoming events, please visit our website at www.thomisticinstitute.org. About the speaker: Fr. Jordan Schmidt was born in Fargo, ND, and attended St. John's University in Collegeville, MN for his undergraduate studies. After entering the Order of Preachers, he came to Washington DC to study theology, graduating from the PFIC in 2009 with an STB/MDiv in theology, and from CUA in 2012 with an STL in biblical theology. Upon his ordination to the priesthood, he was appointed associate pastor of St Mary's parish in New Haven, CT where he served until 2013. Fr. Jordan next returned to the Dominican House of Studies in Washington, DC to pursue doctoral studies at CUA. Since earning his PhD in biblical studies in 2018, he has been teaching various courses in Sacred Scripture at the PFIC.

This lecture was given on December 13, 2022 at Immaculate Conception Church, Washington, D.C. For more information on upcoming events, please visit our website at www.thomisticinstitute.org. About the speaker: Fr. Jordan Schmidt was born in Fargo, ND, and attended St. John's University in Collegeville, MN for his undergraduate studies. After entering the Order of Preachers, he came to Washington DC to study theology, graduating from the PFIC in 2009 with an STB/MDiv in theology, and from CUA in 2012 with an STL in biblical theology. Upon his ordination to the priesthood, he was appointed associate pastor of St Mary's parish in New Haven, CT where he served until 2013. Fr. Jordan next returned to the Dominican House of Studies in Washington, DC to pursue doctoral studies at CUA. Since earning his PhD in biblical studies in 2018, he has been teaching various courses in Sacred Scripture at the PFIC.

*Partnered contentIn Boston, Massachusetts, one company is now making significant headway in the development of an innovative treatment for rare pediatric liver diseases.Led by president and chief executive officer Ron Cooper, Albireo (Nasdaq: ALBO) has since 2021 boasted both US and EU approval for the novel bile acid modulator Bylvay (odevixibat).The oral medicine addresses an unmet need by providing the first non-surgical treatment option for people with progressive familial intrahepatic cholestasis (PFIC), a rare genetic disorder affecting young children that causes progressive, life threatening liver disease.Bylvay is approved for the treatment of pruritus in PFIC in the USA, and for PFIC in Europe.The company has also recently announced positive top-line results from the Phase III ASSERT study, which is testing Bylvay in Alagille syndrome (ALGS), another rare genetic disorder.Approval in ALGS would open up another source of revenue for the product, and offer hope for families impacted by this serious condition, which affects multiple organ systems including the liver and heart.Estimates vary for the therapy's peak revenue potential, but most analysts suggest the product will be able to generate hundreds of millions in annual sales, should all go according to plan.As well as transforming the treatment of rare conditions with a high disease burden, such an outcome would enable the company to more fully explore the science of IBAT inhibition, an approach which it believes has great potential in a wide range of cholestatic liver diseases.In this week's episode of The Pharma Letter Podcast, I'm pleased to be joined by Ron Cooper, for a discussion of his company's clinical goals and strategic focus.

Welcome to the fifty eighth episode of #Expatchat where we discuss the latest tax and financial issues affecting an #Australianexpat. In today's Expat Chat we continue our theme of financial considerations that US based Australian expats need to consider and talk about investment considerations that they need to make when managing their wealth. The term Passive Foreign Investment Company (PFIC) is a phrase that many Australian expats maybe unaware of but it is crucial that they learn about it if they are looking to manage their investment and/or growth their wealth living in the United States. The US is almost famous for their quirky tax laws when compared to other countries and the rules surrounding investment consideration are no different for Australian expats. Whilst there maybe a number of financial and tax incentives in the US to participate in these retirement plans its important that Australian expats understand how they work, and if you are considering cashing them in when you are leaving the US, what are the considerations. In this episode we run through the following topics: • What is a PFIC? • What tax considerations do Australian expats need to consider when holding PFIC's? • How do you avoid the complications of holding a PFIC? • What is the difference between a employee benefits trust and foreign grantor trust? Links that we discussed in this episode include: • Ask Atlas - Have your questions answered on the podcast by clicking this link - https://atlaswealth.com/news-media/australian-expat-podcasts/questions-or-feedback-for-the-expat-podcast/ • Expat Mortgage Podcast - https://atlaswealth.com/news-media/australian-expat-podcasts/expat-mortgage-podcast/ If you like the content make sure you let us know by hitting the thumbs up and subscribing as well as providing some feedback in the comments below. Atlas Wealth Management is a specialist in providing tax financial planning advice to every Australian #expat. Whether you are based in Asia, the Middle East, Europe or the Americas, we have the experience in providing wealth management and planning services to the expatriate community. Atlas Wealth Management was born out of the demand from expats who wanted a financial adviser to help them navigate the tax and financial maze of living abroad as well as assisting them make the most out of their time overseas. To find out more about Atlas Wealth Management and how we can help Australian expats please go to https://www.atlaswealth.com. Make sure you connect with us on our respective social media channels: Facebook: www.facebook.com/atlaswealthmgmt LinkedIn: www.linkedin.com/company/atlas-wealth-management Twitter: www.twitter.com/atlaswealthmgmt Instagram: www.instagram.com/atlaswealthmgmt

A Colestase intra-hepática familiar progressiva do tipo 3, conhecida pela sigla em inglês PFIC 3, é uma doença rara resultante de uma mutação genética. Neste episódio, eu esclareço dúvidas sobre tratamento, progressão da doença, entre outras. Acesse minhas redes sociais: Facebook, Instagram, YouTube e Site.

Bert's Big Adventure kiddo Kynli and her family are spending so much time at Children's Healthcare of Atlanta, they had to move closer to the hospital, which has been a financial strain for the entire family. Let's see if we can help them out here with the help of the Justin Landis Group!Kynli is the youngest of three children who all have PFIC: Progressive Familial Intrahepatic Cholestasis, a disease that has resulted in liver failure and liver transplants in all three children. Her oldest sister, Kayli, was about 2 months old, when her mom, Kari, returned to work after maternity leave and dropped her off at daycare for her first day. When picking her up, a daycare employee pointed out how yellow she appeared and suggested she visit a doctor.They took Kayli to a liver specialist who diagnosed her with PFIC, which is very rare. At that time, all the doctors were able to tell her was that children with that condition weren't expected to live past 10 years old without a liver transplant. Despite extremely rare odds, her second and third children were diagnosed with the same disease and all three children have had liver transplants and go in for testing monthly.Kari's ex-husband was discharged from the military when they were living in Tacoma, Washington, and he decided to move to Qatar, where he still resides. Since Tacoma had a high cost of living, Kari made the decision to move with the kiddos. She had never lived in Atlanta but settled in Conyers to be close to Children's Healthcare of Atlanta. It's hard for the family to get ahead monetarily because the rent keeps increasing, but they have to live close to CHOA and all of the children need to have separate rooms since they frequently have to quarantine. They also don't often appear sick so classmates question why they get special treatment.The Justin Landis Group has helped thousands of clients over the years, and each has come to us with a unique dream. They've helped empty-nesters looking to downsize and young families looking for more space as they grow. Some people hope for a great yard, while others search for a high-rise condo in the heart of the city. For some of our city's most vulnerable, much like Kynli and her family, the dream is a little different.When the team at The Justin Landis Group heard about Kynli and her family, they knew they had to step in and help. That's why the Justin Landis Group is going to gift Kynli and her family 3-months of rent/mortgage payments!They told us "We believe they deserve their dream just as much as anyone else, which is why we are proud to partner with Bert's Big Adventure." See acast.com/privacy for privacy and opt-out information. Become a member at https://plus.acast.com/s/the-bert-show.

Bert's Big Adventure kiddo Kynli and her family are spending so much time at Children's Healthcare of Atlanta, they had to move closer to the hospital, which has been a financial strain for the entire family. Let's see if we can help them out here with the help of the Justin Landis Group!Kynli is the youngest of three children who all have PFIC: Progressive Familial Intrahepatic Cholestasis, a disease that has resulted in liver failure and liver transplants in all three children. Her oldest sister, Kayli, was about 2 months old, when her mom, Kari, returned to work after maternity leave and dropped her off at daycare for her first day. When picking her up, a daycare employee pointed out how yellow she appeared and suggested she visit a doctor.They took Kayli to a liver specialist who diagnosed her with PFIC, which is very rare. At that time, all the doctors were able to tell her was that children with that condition weren't expected to live past 10 years old without a liver transplant. Despite extremely rare odds, her second and third children were diagnosed with the same disease and all three children have had liver transplants and go in for testing monthly.Kari's ex-husband was discharged from the military when they were living in Tacoma, Washington, and he decided to move to Qatar, where he still resides. Since Tacoma had a high cost of living, Kari made the decision to move with the kiddos. She had never lived in Atlanta but settled in Conyers to be close to Children's Healthcare of Atlanta. It's hard for the family to get ahead monetarily because the rent keeps increasing, but they have to live close to CHOA and all of the children need to have separate rooms since they frequently have to quarantine. They also don't often appear sick so classmates question why they get special treatment.The Justin Landis Group has helped thousands of clients over the years, and each has come to us with a unique dream. They've helped empty-nesters looking to downsize and young families looking for more space as they grow. Some people hope for a great yard, while others search for a high-rise condo in the heart of the city. For some of our city's most vulnerable, much like Kynli and her family, the dream is a little different.When the team at The Justin Landis Group heard about Kynli and her family, they knew they had to step in and help. That's why the Justin Landis Group is going to gift Kynli and her family 3-months of rent/mortgage payments!They told us "We believe they deserve their dream just as much as anyone else, which is why we are proud to partner with Bert's Big Adventure." See acast.com/privacy for privacy and opt-out information. Become a member at https://plus.acast.com/s/the-bert-show.

This week's episode is a very exciting interview with Chris Peetz, CEO of Mirum Pharmaceuticals! Mirum helps create drugs and treatments for rare liver conditions, including Alagille Syndrome, progressive familial intrahepatic cholestasis (PFIC) and biliary atresia. Mirum just had an exciting breakthrough with the approval of their drug LIVMARLI, which treats the chronic itch that many ALGS patients suffer from. Chris and I talked a lot about LIVMARLI and where Mirum is taking this success, the logistics of drug approval overseas, how Chris started at Mirum, and much much more! ------- A little bit more about Chris Peetz: Chris Peetz is a co-founder of Mirum and serves as president and chief executive officer. Chris has been an entrepreneur-in-residence at Frazier Healthcare Partners since May 2017. Prior to joining Mirum, Chris served as the chief executive officer of Flashlight Therapeutics, Inc. From May 2014 to December 2016, he served as chief financial officer and head of corporate development at Tobira, which was acquired by Allergan plc, in November 2016. Prior to joining Tobira, Chris served as vice president, finance and corporate development of Jennerex Biotherapeutics. Prior to Jennerex, Chris held various positions at Onyx Pharmaceuticals, Inc. (now Amgen Inc.), including corporate strategy, marketing, product lifecycle management, and financial planning. Prior to Onyx, Chris provided merger and acquisition advisory services at LaSalle Corporate Finance, a part of ABN AMRO, and held positions at Abgenix Inc. and Solazyme Inc. He also serves as a member of the board of directors of Alpine Immune Sciences, Inc., a public immunotherapy company, since April 2018. Chris received an M.B.A. from Stanford Graduate School of Business and a B.S.B.A. in Finance, International Business and French from Washington University in St. Louis. ------- Be sure to subscribe to R is for Rare on Apple Podcasts, Spotify, or wherever you get your podcasts! Follow me on Instagram -- https://www.instagram.com/risforrarepodcast/?hl=en Questions? Want to be a guest on the podcast? Email me: risforrarepodcast@gmail.com  --- This episode is sponsored by · Anchor: The easiest way to make a podcast. https://anchor.fm/app --- Send in a voice message: https://anchor.fm/annie-watson/message

The Ernst & Young ITTS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: Biden Administration looks to scaled-back Build Back Better legislation – House Ways and Means Committee Republicans warn congressional consent needed for BEPS 2.0 Pillars –  Final regulations released on treatment of domestic partnerships under Section 958, proposed PFIC regulations – IRS amends instructions for 2021 partnership Schedules K-2 and K-3, relevant to private equity, private capital funds – IRS announces fast-track pilot program to resolve corporate LTR requests in 12 weeks – US officials comment on cryptocurrency efforts – BEPS 2.0 model rules commentary expected to be released soon – OECD developing BEPS 2.0 Pillar Two corporate minimum tax implementation framework – OECD publishes 2022 Transfer Pricing Guidelines – OECD releases eighth batch of Stage 2 peer review reports on dispute resolution.

A review of the week's major US international tax-related news. In this edition: Sen. Manchin confirms Build Back Better discussions back on – Concern over double taxation if US GILITI unamended – Republican tax writers warn BEPS Pillars require  congressional action – Treasury releases final regulations on treatment of domestic partnerships under Section 958, proposed PFIC regulations – OECD developing BEPS 2.0 Pillar Two corporate minimum tax implementation framework.

Our guest this week is Jeremy Knakmuhs of Colorado Springs, CO who is a structural project engineer at CTL Thompson. Jeremy and his wife, Emily, have been married for 8 years and are the proud parents of three children: Colton (6), and three year old twins: Remi and Kennedy, who has PFIC, which is Progressive Familial Intrahepatic Cholestasis, a rare genetic liver disorder that affects infants and children. We'll hear the Knakmuhs family story and how Jeremy and Emily have navigated the ups and downs of raising three children, including one with special needs. That's all on this Special Fathers Network Dad to Dad Podcast. PFIC Network – https://www.pfic.org Alberio Pharma - https://www.albireopharma.com PFIC Voices (An educational resource created by Albireo)- https://www.pficvoices.com/Donate Life Colorado - https://www.donatelifecolorado.org Special Fathers Network - SFN is a dad to dad mentoring program for fathers raising children with special needs. Many of the 500+ SFN Mentor Fathers, who are raising kids with special needs, have said: "I wish there was something like this when we first received our child's diagnosis. I felt so isolated. There was no one within my family, at work, at church or within my friend group who understood or could relate to what I was going through."SFN Mentor Fathers share their experiences with younger dads closer to the beginning of their journey raising a child with the same or similar special needs. The SFN Mentor Fathers do NOT offer legal or medical advice, that is what lawyers and doctors do. They simply share their experiences and how they have made the most of challenging situations. Special Fathers Network: https://21stcenturydads.org/about-the-special-fathers-network/Check out the 21CD YouTube Channel with dozens of videos on topics relevant to dads raising children with special needs - https://www.youtube.com/channel/UCzDFCvQimWNEb158ll6Q4cA Please support the SFN. Click here to donate: https://21stcenturydads.org/donate/

Brent and Rachel discuss several themes circulating in the media (conventional and social). First, they discuss the proposed Billionaire Tax and how it appears to look a lot like the existing PFIC rules. Second, they discuss the review of GRATs, IDGTs, valuation discounts, and CLATs used by Phil Knight, as discussed in Businessweek https://www.bloomberg.com/features/how-billionaires-pass-wealth-to-heirs-tax-free-2021/. After recording, the Senate Finance Committee released the text of the billionaire tax, which can be found here: Click to access Billionaires%20Income%20Tax.pdf

Episode 100: Today is a very special day. PI-Perspectives is officially releasing its 100th episode. Make sure you take advantage of the Toolbox code and give away. Today, we bring back one of the original guests when Matt started this program. Joining us today is Amber Schroader from Paraben. Paraben is the leading Cellphone Forensics company in the industry and offers amazing resources and training. Matt catches up with Amber today and they discuss the PFIC event in Utah in September. If you are in the Cellphone Forensic world or you wish to dive into it, you need to attend this event either in person or virtually. Paraben consistently leads the way in this sector. Please welcome Ginger Wonder Mom, Amber Schroader and your host, Private Investigator, Matt Spaier Links:     Matt's email: MatthewS@Satellitepi.com  Linkedin: Matthew Spaier    www.investigators-toolbox.com  Amber on Linkedin: Amber Schroader amber@paraben.com twitter: @gingerwondermom https://paraben.com/ https://pfic-conference.com/ PI-Perspectives Youtube link: https://www.youtube.com/channel/UCYB3MaUg8k5w3k7UuvT6s0g Sponsors:     https://apps.crosstrax.co/signup/index/refcd/LY3R7VUW69 https://merlinlocate.com/ https://piinstitute.com/ https://www.skopenow.com/

A question that I'm asked frequently these days is “how do I handle my American investments from overseas if my current American brokerage firm wants to close my account?” It's common for me to get inquiries from people who received letters about their accounts being closed/frozen. Happily, I can help them. While many American firms are dismissing clients with foreign addresses, we welcome the strengthening of international relationships. We custody our clients' accounts at Pershing, LLC. Member NYSE/SIPC, a subsidiary of the Bank of NY Mellon Corp. That means that all the assets are held in America, the statements are all in English, and all the accounts are compliant with IRS regulations. Beware of moving assets to Israel! Not only will tax-deferred accounts like IRAs lose their U.S. tax-deferred status, but U.S. PFIC regulations can make it very costly to invest in Israeli funds. Bottom line: there are two easy steps to handle your American investments from overseas: Listen to this week's podcast Be in touch with me (call my Jerusalem office 02-624-2788 or fill in the contact form)

Cedar, who was named after a tree, has achieved a lot in her almost-decade of being alive—she has a podcast, she’s sort of a Do-It-Yourself queen, an accomplished video game champion (thanks to Covid), and she likes a lot of, you know, normal kid stuff—not including getting a liver transplant at the age of five.   Cedar has something called Progressive Familial Intrahepatic Cholestasis, otherwise known as PFIC 2. This devastating genetic disorder affects 1 in 50,000 to 1 in 100,000 live births and, if untreated, can be fatal by the age of twenty. Visit pfic.org for more information. This mini-episode is brought to you by Deuter USA, Gnarly Nutrition, Allez Outdoors, First Ascent Coffee, and Patagonia. Music by: Kakurenbo and Podington Bear. Additional music licensed by Music Bed. A HUGE thank you to Chad Crouch for creating absolute magic and to Peter Darmi for mixing this episode. Additional sound effects from zapsplat.com. Cover photo by Kika MacFarlane. Read the transcript here. Follow us on Instagram for podcast (pod-Kath?) updates and general life things. Support us on Patreon in exchange for a warm, fuzzy feeling.

Today I'm sharing an interesting conversation I had with Ron Zalben of Aboulafia Avital Shrensky & Co. CPAs about a big issue that not only impacts American Olim living in Israel, but all Americans living abroad. Do you invest locally? If so you should be careful as you may be investing in a PFIC. What is a PFIC and what are the tax ramifications for investing in them? Also, make sure to watch this whole episode of The Aaron Katsman Show for our expert recommendations and best practices when it comes to investing as an expat. Aaron Katsman is a licensed financial professional both in the U.S. and Israel. Call 02-624-0995 for a consultation on how to handle U.S. brokerage accounts from Israel. This video is for education purposes only and is not intended to give investment, legal or tax advice. If such advice is needed, contact a licensed professional who can help you. Securities offered through Portfolio Resources Group Inc. Member FINRA, SIPC, MSRB, FSI. The opinions expressed are those of the author and not of Portfolio Resources Group Inc., or its affiliates. Neither PRG nor its affiliates give tax or legal advice. You can reach me at connect with Aaron at: aaron@lighthousecapital.co.il or visit www.aaronkatsman.com

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Thomas Groenen (PwC's US ITS-Financial Services Leader) discuss the renewed interest in special purpose acquisition companies (SPACs). Doug and Thomas cover: how Thomas made his way from the UK to the US; Thomas's advice for individuals interested in moving to the United States to become tax professionals; what a SPAC is and how it generally functions; the history of SPACs—dating back to the British 'South Sea bubble' in the early 18th century; how SPACs compare to and interrelate with IPOs; how and why individuals and entities invest in SPACs; the tax implications for SPAC investors; considerations regarding the SPAC's jurisdiction; the SPAC lifecycle, from founding to de-SPACing; the importance of choosing the correct investment vehicle (both corporate v. pass-through and domestic v. foreign); how the passive foreign investment company (PFIC) regime interplays with foreign SPACs; and the possible future of SPACs.­

Francesca è la mamma di due bambini, Erneto ed Eva Luna. Quando sua figlia aveva 4 mesi le è stata diagnosticata una malattia rara: la colestasi intraepatica familiare progressiva, detta anche PFIC. Una patologia invalidante, poco conosciuta, che non permette ad Eva Luna di vivere la sua infanzia come tutti gli altri bambini della sua età.Nella foto il Dott. Jean de ville de goyet con Eva Luna e sua mamma FrancescaPer maggiori informazioni sull'associazione, la storia di Eva Luna e di altri bambini che soffrono di PFIC https://www.facebook.com/Pfic-Italia-Network-Colestasi-Intraepatica-Familiare-Progressiva-119926143248325/?ref=page_internalSe vuoi fare una donazione per aiutare la ricerca su questa malattia rarahttps://www.gofundme.com/f/Ferma-il-prurito-pfic-italia-network

The Ernst & Young ITS Washington Dispatch brings you a monthly review of US international tax-related developments. In this edition: US Congress passes coronavirus stimulus and omnibus spending package, including extension of CFC look-through – IRS issues final and proposed PFIC regulations – Treasury to focus on other international projects, tax treaties as TCJA guidance nears completion – Treasury’s FinCEN further extends certain FBAR signature authority reporting over foreign financial accounts – IRS will continue ICAP joint risk assessment initiative – US transfer pricing enforcement remains priority while TCJA provisions may negate adjustments – IRS APMA seeing more queries on transfer pricing consequences of coronavirus pandemic – BEPS 2.0 Pillar One and Two comment period closes; public consultation set for 14-15 January 2021 – OECD issues guidance on transfer pricing implications of COVID-19, hard-to-value intangibles – OECD releases fourth peer review report on BEPS Action 5 on Exchange of Information of Tax Rulings – OECD’s FTA hosts virtual meeting of tax administration leaders.

A review of the week's major US international tax-related news. In this edition: OECD to hold virtual public consultation on BEPS 2.0 Pillar 1 and Pillar 2 Blueprints on 14-15 January 2021 – IRS releases final and proposed PFIC regulations – IRS issues final regulations under Sections 245A and 951A that coordinate two sets of anti-abuse rules – IRS LB&I releases internal guidance re: examinations with Section 965 transition tax issues.

Episode 52:    Welcome to the 1-year anniversary show. Before we get started, we wanted to sincerely thank you, the listener for supporting the show, supporting our sponsors and for helping this show grow at an incredible rate. As you heard, we are celebrating today with some giveaways. You can enter to win a free seat at Paraben’s PFIC conference next week. Stick around till the end and find out how to win a free subscription to the Investigators toolbox. Our guest today is Chris Salgado from All Points Investigations. Chris the former managing Investigator at Facebook. The guys discuss research methodology and how to approach research in an efficient manner. Chris also writes for PI Magazine. Let’s get the show on the road. Please welcome Chris Salgado and your host, Private Investigator, Matt Spaier Links:     Matt’s email: MatthewS@Satellitepi.com  Linkedin: Matthew Spaier    www.investigators-toolbox.com  Chris’ email: info@allpointsinv.com Linkedin: Christopher Salgado Sponsors:      https://www.usabugsweeps.com  https://www.crosstrax.co/    www.delvepoint.com

Even as an Expat, you still need to file a tax return and, depending on your income, pay taxes, as long as you have a U.S. citizenship. Your worldwide income is taxable even if you filed a tax return and paid taxes in the country where you reside. If your taxable income is over $20,000 a year and you are married; or $10,000 and single; or made over $400 per year as self-employed or contractor, you need to file a tax return. Check the Video Version Click Here For More Info

Met vandaag: de media in Oostenrijk | spanning aan de Turks-Syrische grens | voorverkiezingen South Carolina | Frans van Deursen over zijn overleden vriend Bob Fosko | Morgen begint de meteorologische lente | Aandacht voor de zeldzame ziekte PFIC-2. Presentatie: Marcia Luyten.

Amber Schroader is a true pioneer in the digital forensics industry. She has over 30 years of experience in the field, which is amazing given the state of technology at that time, the change in technology over the years and the fact that her company, Paraben Corporation is celebrating its 20th year anniversary this year! Congratulations of your accomplishments Amber! A few months ago when I was brainstorming the idea that eventually turned into this podcast, I posted a comment in a Digital Forensics Facebook group to see if there would be any guests I could have on the show. I received a polite response from another member in the group saying she would like to help and give me a list of people to contact and ideas for content. I was so impressed by this gesture, but when I asked my new friend what she did, her response, "I own Paraben and we do tech and digital forensics." Since I was VERY familiar with Paraben, it's products and services, I was amazed to make such a connection in a common Facebook group about our field. But, that's Amber. After all this time, after all her accomplishments, she is so passionate about our field that she is still involved in as much as she can be about this field - Facebook groups, YouTube videos, presentations and putting on her amazing conference PFIC, now in it's 13th year. Amber was a very interesting guest and touched on some interesting and real issues, like her less than ideal treatment as a woman in her profession. She is a genuine person, my fellow ginger & dog lover, an inspiring business woman and deserves all the success that she has worked so hard to achieve. If you want to learn more about Amber Schroader and her company, Paraben Corporation please visit paraben.com and connect with them on social media: Twitter LinkedIn YouTube Facebook --- Send in a voice message: https://anchor.fm/dfiforensics/message

US Senate approves amending tax protocols with Luxembourg, Switzerland, Japan and Spain – US considers retaliation against France’s new DST – IRS issues proposed PFIC regulations – IRS releases final regulations for allocating partnerships’ creditable foreign tax expenditures – IRS sending warning letters to virtual currency owners – IRS issues information on Section 965 filing and payment – Altera Corporation files petition for rehearing of cost sharing case in Ninth Circuit

A review of the week's major US international tax-related news. In this edition: US government initiates review of France’s new DST tax; possible retaliatory action – US Senate to consider tax protocols with Spain, Switzerland, Japan, and Luxembourg week of 15 July 2019 – IRS issues major proposed PFIC regulations

Do PFICs (Passive Foreign Investment Companies) deserve a bad rap? Why do Doug and his guests tell listeners “don’t invest in PFICs.” Today’s guest, Stacy Collier, will explain exactly why an investor should avoid PFICs, otherwise known as offshore mutual funds. Stacy Collier, a U.S. based CPA, specializes in helping U.S. citizens manage their money from abroad. Stacy outlines the good, the bad, and the ugly about PFICs. She explains how the IRS. deals with PFICs and describes the red tape that owning a PFIC create. Before you invest in any investment, know the pros, cons, and risks. Should we read your listener letter? Doug answers a listener’s question about portfolio structure. “Rich” asks if it’s a good idea to change your asset allocation later in life. Doug offers insight into bonds and bond funds and explains how Rich’s investments are affected by the difference. Learn more about Stacy Collier and PFICs by downloading this chart, or visiting her website SDC CPA Tax Services. If you’re not already receiving updates on new episodes, sign up now, and as a special bonus, receive Doug’s free ebook The Retirement Planning Book.

Investors used to be able to buy PFICs (passive foreign investment corporations) investments without a lot of trouble. So what changed? Yosefa Huber, CPA, helps U.S. citizens living abroad sort out tax issues regarding their U.S. investments. Doug and Yosefa discuss why PFICs cause so much trouble to investors and their accountants. Learn what a PFIC is, and then take a look at your investment portfolio to see if you inadvertently own one. Should you try to retire early and enjoy life? Doug has 3 Reasons Not to Retire Early, and they may be more legitimate than you realize. Free download: 3 Reasons Not to Retire Early Yosefa Huber can be contacted through her website and Facebook. If you’re not already receiving updates on new episodes, sign up now, and as a special bonus, receive Doug’s free ebook The Retirement Planning Book.

PFIC is a rare genetic disorder that causes progressive, life-threatening liver disease. In many cases, PFIC leads to cirrhosis and liver failure within the first 10 years of life. Albireo, a 2008 spin-out of AstraZeneca, is developing bile acid modulators to treat PFIC and other rare pediatric liver diseases and gastrointestinal disorders. We spoke to Ron Cooper, CEO of Albireo, about PFIC, the challenge of developing a therapy for a disease with multiple forms and causes, and the path forward for the company.

Congress, incoming Trump Administration prepare for tax reform * Temporary and proposed regulations on covered asset acquisitions issued under Section 901(m) * Final and temporary US FX regulations issued * Final regulations retroactively eliminate Section 367(d)'s exception for foreign goodwill and going concern value * IRS releases extensive FATCA-related guidance * IRS issues final PFIC regulations * IRS finalizes regulations requiring reporting by foreign-owned US disregarded entities * IRS Notice 2016-73 announces amendments to Section 367 regulations applying to certain cross-border triangular reorganizations and inbound nonrecognition transactions * IRS issues Section 871(m) transition rules in Notice 2016-72 * IRS Notice 2017-07 modifies effective date for deferral events and outbound loss events * US, India reached agreement in first bilateral APA.

A review of the week's major US international tax-related news. In this edition: Congress returns for 115th Congress and US tax reform debate – IRS issues final PFIC regulations – US, Argentina sign Tax Information Exchange Agreement.

US international tax reform, repatriation considered to pay for Highway Trust Fund -- Congressional tax leaders express BEPS project concerns -- Bill introduced to close PFIC ‘loophole’ -- IRS issues final Section 7874 regulations; retains bright-line rule of SBAT -- IRS reiterates that principles of Notice 2012-39 retroactively apply to outbound F reorgs with CFC shareholder -- OECD releases discussion draft on hard-to-value intangibles under BEPS Action 8 -- OECD issues implementation package for CbC reporting under BEPS Action 13 – Seven more countries agree to Common Reporting Standard.

A review of the week's major US international tax-related news. In this edition: House W&M subcommittee hearing looks to repatriation to fund Highway Trust Fund – Senate Finance Committee working group on international tax reform hands in report – Legislation introduced to close PFIC “loophole” reportedly used by US hedge fund reinsurers.

A review of the week's major US international tax-related news. In this edition: IRS issues proposed PFIC insurance regulations that address Senate Finance Committee member’s concerns – IRS releases proposed regulations under Section 5000C – IRS CCA 201516064 clarifies short term loan exception under IRS Notice 88-108.

A review of the week's major US international tax-related news. In this edition: Senate Finance international tax working group reviewing options - IRS confirms interaction of PFIC look-through rules in PLR 201515006 - OECD releases discussion draft on Action 11(Improving the analysis of BEPS).

Congress returned from August recess to debate corporate inversions, Treasury took action -- OECD releases 2014 output of BEPS Action Plan -- IRS CCA concludes accrued but unpaid interest constitutes an obligation of US person for Section 956 purposes -- IRS exempts certain holders of PFIC stock that is mark to market from Section 1298(f) filing

A review of the week's major US international tax-related news. In this edition: IRS issues Notice 2014-52 to counter corporate inversions -- Treasury considering expanding covered asset acquisition rules under Section 901(m); PFIC guidance coming -- EY Alerts / Webcasts on OECD BEPS deliverables available -- Congress adjourns for mid-term elections; lame duck session may bring tax technical corrections.

A review of the week's major US international tax-related news. In this edition: Congress returns from August recess; focuses on anti-inversion options -- OECD to release first seven deliverables under BEPS Action Plan on 16 September 2014 -- IRS issued CCA 201436047; accrued but unpaid interest is an obligation under Section 956 -- IRS Notice 2014-51 announces PFIC marked to market exception

Tax extenders legislation update -- IRS Notice 2014-32 announces amendments to final regulations under Sections 367(a) and 367(b) -- IRS announces FATCA relief treating certain pending IGAs as in effect -- Notice 2014-31 extends PFIC active banking exception for qualifying government bonds -- US persons holding PFIC stock through exempt organizations / accounts exempt from Form 8621 filing -- IRS issues annual APA report -- Pending US tax treaties reported out of committee -- US, Hong Kong sign TIEA -- Official offers US government position on BEPS action items

A review of the week's major US international tax-related news. In this edition: House Ways and Means Committee to mark-up tax extenders soon -- Senate tax extenders bill to go to floor week of 28 April -- IRS Notice 2014-32 addresses foreign triangular reorganizations -- IRS extends expanded PFIC active banking exception for qualifying government bonds.

A review of the week's major US international tax-related news. In this edition: IRS announces filing exemption for US persons holding PFIC stock through exempt orgs / accounts -- Immediate action for Mexican IMMEX/maquiladora companies.

Congress reconvenes in January, passes "omnibus" appropriations bill -- President Obama delivers States of the Union and calls for corporate tax reform -- IRS issues temporary and proposed anti-inversion regulations -- IRS releases final FATCA Foreign Financial Institution Agreement -- IRS issues temporary and proposed PFIC regulations -- Final and proposed regulations on dividend equivalent payments on notional principal contracts and other equity-linked instruments issued -- US signs 7 FATCA intergovernmental agreements -- OECD releases draft country-by-country reporting template for comment -- OECD provides an update on the BEPS Action Plan; digital economy focus still on track

A review of the week's major US international tax-related news. In this edition: IRS issues temporary and proposed PFIC reporting regulations -- Congress to reconvene second sesssion of 113th Congress -- Two international tax extenders expired on New Year's Eve.

Amber Schroader, CEO of Paraben Corporation, sat down with Josh Gilliland to talk about the Paraben Forensic Innovation Conference, eDiscovery, computer forensics and being a geek.Support the show (https://www.patreon.com/thelegalgeeks)

November elections leave status quo unchanged for “fiscal cliff” talks - Treasury issues second Model FATCA Intergovernmental Agreement -- FATCA negotiations moving forward -- REIT’s Subpart F and PFIC inclusions qualify under 95% income test -- IRS releases 2012 - 2013 Business Plan

The Legal Geeks at PFIC 2012 with Judge Matthew Sciarrino. Josh Gilliland, Jessica Mederson and Judge Sciarrino discuss comic book super heroes, Firefly and Star Wars. No part of this recording should be consider legal advice, nor an endorsement of being a super hero.Support the show (https://www.patreon.com/thelegalgeeks)

Congress reviews tax reform options; territorial tax system enters presidential politics -- US Treasury releases FATCA Model Intergovernmental Agreement -- IRS Notice 2012-39: future regs coming under Section 367(d) affecting outbound transfers of intangible property in asset reorganizations -- IRS regulations clarify prior guidance on ODLs, coordinate with OFL and SLL provisions -- IRS expands PFIC active banking exception for qualifying government bonds -- IRS changes ITIN application procedures