Podcasts about pfic

Portugal has become one of the most popular destinations for Americans moving abroad, but the move is not always as simple as it looks. From visas and tax residency to Golden Visa funds, PFIC reporting, retirement accounts and recent citizenship changes, there are plenty of details that can catch Americans out if they do not plan properly.  Richard Taylor - dual UK/US citizen and Chartered Financial Planner - is joined by Zeev Fisher - an international advisor and founder of Fresh Legal Group - a boutique firm specialising in international wealth and cross-border tax. Together, they unpack what Americans need to know before moving to Portugal, especially those navigating US tax, expat tax advice, and complex cross-border rules.  They break down the key visa routes for Americans, including the D7 passive income visa and the D8 digital nomad visa, and when a Golden Visa makes sense. They also explain how PFIC rules can create unexpected US tax issues, why using retirement funds for a Golden Visa investment can trigger serious penalties if done incorrectly, and how these decisions fit into broader cross border financial planning.  Richard and Zeev also discuss Portugal's new tax regime replacing the former non-habitual resident system, and what it means in practice for Americans moving over today. Finally, they break down the recent citizenship rule changes and why they have become such a major issue for current and future expats, particularly those thinking long term about expat retirement planning or building a life overseas.  –  Expat Wealth is supported by Plan First Wealth. Plan First Wealth is a Registered Investment Advisor serving fellow expatriates and immigrants living across the US on matters such as retirement planning, investment management, tax planning and non-US asset management.  https://planfirstwealth.com/  –  Expat Wealth 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. 

The Ultimate Guide for Americans Moving to Spain: Visas, Taxes, and Cross-Border Financial Planning By AIO Financial — Fee-Only Fiduciary Financial Planners Spain has quietly become one of the most popular destinations for Americans relocating abroad. The lifestyle is compelling — long lunches, walkable cities, world-class healthcare, sunshine, and a cost of living that, in many regions, runs 20–30% below comparable U.S. cities. But behind that lifestyle is a tax and regulatory system that can blindside Americans who move without proper planning. We work with U.S. expats every week at AIO Financial, and the same patterns keep showing up. People sell investments at exactly the wrong moment. They convert Roth IRAs and trigger Spanish tax bills they didn’t know existed. They open European brokerage accounts and accidentally buy PFICs. They miss the six-month window for the Beckham Law and lose six figures of potential tax savings. None of this is necessary. Almost every cross-border financial mistake we see is preventable with planning that starts twelve to eighteen months before the move — not after the boxes are unpacked in Valencia. This guide walks through what we believe every American family should understand before moving to Spain: the visa landscape after the Golden Visa was eliminated, how Spain actually taxes Americans (including the surprising treatment of Roth IRAs), what to do with your investments before you become a Spanish tax resident, and how to think about banking, currency, and cash transfers across borders. None of this is legal or tax advice for your specific situation, but it should give you a real working framework before you sit down with a cross-border specialist. Why Americans Are Moving to Spain Right Now The reasons people give us are remarkably consistent. They want better work-life balance. They want their kids to grow up bilingual. They’ve watched U.S. healthcare costs spiral and want a system that just works. They’re approaching retirement and the math on living in coastal Spain versus coastal Florida is hard to argue with. A few are motivated by political concerns; many simply want to live somewhere that feels less hurried. What makes Spain particularly attractive compared to other European destinations is the combination of a well-functioning Digital Nomad Visa, a meaningful (if imperfect) tax treaty with the United States, and a cost-of-living advantage that still holds up despite recent inflation. A single person can live comfortably in mid-sized Spanish cities like Valencia, Granada, or Málaga on roughly €1,600–€1,900 per month. Madrid and Barcelona cost more, but still less than San Francisco, Boston, or Seattle. The catch — and this is the part most relocation guides skip — is that Spain has a wealth tax, taxes worldwide income for residents, does not respect the U.S. tax-free status of Roth IRAs, and uses a fiscal-year structure that can leave new arrivals exposed to a full calendar year of Spanish taxation if they cross the 183-day threshold without realizing it. Done well, moving to Spain can be one of the best financial and lifestyle decisions a family makes. Done poorly, it can be a multi-year tax mess. Visa Pathways: What’s Available in 2026 Before any tax planning matters, you need legal residency. Spain offers several pathways for non-EU citizens, and the right one depends on whether you’re working, retired, or have substantial passive income. The Digital Nomad Visa (DNV) The Digital Nomad Visa, introduced under Spain’s 2023 Startup Act, has become the most popular route for working-age Americans. It allows non-EU remote workers — both employees of foreign companies and self-employed freelancers — to live legally in Spain while working for non-Spanish employers or clients. As of 2026, the income threshold is set at 200% of Spain’s Minimum Interprofessional Salary, which works out to approximately €2,850 per month, or roughly €34,200 per year. Most Spanish consulates recommend showing at least €3,000 monthly to account for currency fluctuations. If you’re applying with family, the income requirement increases. You’ll need to demonstrate an additional 75% of the SMI (about €1,035 per month) for your first dependent — typically a spouse — and 25% for each additional family member. A family of four moving together generally needs to show somewhere around €4,400 per month in qualifying income. The DNV initially issues a residence authorization valid for up to three years if applied for from within Spain, or a one-year visa if applied for through a Spanish consulate abroad. It can be renewed for additional periods, allowing total stays of up to five years, after which permanent residency becomes available. Citizenship is generally available after ten years of legal residency for U.S. nationals (two years for citizens of Latin American countries, the Philippines, Andorra, and a handful of others). Other key requirements include having worked with your current employer or clients for at least three months before applying, holding either a relevant university degree or three years of professional experience in your field, working for a company that has been in operation for at least one year, and earning no more than 20% of your income from Spanish sources. The application process typically takes four to five months. One important wrinkle for Americans: the U.S.–Spain Totalization Agreement does not currently cover remote work in the way that some other bilateral agreements do, so the U.S. Social Security Administration rarely issues Certificates of Coverage for DNV applicants. Most U.S. W-2 employees need to either get their employer to set up a Spanish “shadow payroll” arrangement, switch to 1099 contractor status and register as an autónomo (self-employed) in Spain, or accept that they’ll be paying into the Spanish social security system. This is a frequent friction point and is best resolved before the move, not after. The Non-Lucrative Visa (NLV) The Non-Lucrative Visa is the traditional retiree route — and increasingly used by Americans of any age with sufficient passive income. It explicitly does not permit working in Spain or remotely for any employer, which is its main limitation. As of 2026, applicants need to show approximately €2,400 per month (around €28,800 per year) in passive income or savings, with additional financial requirements for dependents. For genuinely retired Americans drawing Social Security, pension income, or living off investment portfolios, this is often the cleanest path. It comes with one substantial caveat that we’ll return to in the tax section: NLV holders are not eligible for the Beckham Law, so they pay full progressive Spanish tax rates on worldwide income from day one. The Golden Visa Is Gone If you’ve been planning around Spain’s Golden Visa — the residency-by-investment program that previously offered residency in exchange for a €500,000 real estate investment — that program ended in April 2025 as part of housing market reforms. New applications are no longer accepted. Existing Golden Visa holders retain their residency, but anyone considering this route now needs to look at alternative visas, or alternative countries (Portugal and Greece still operate similar programs, though Portugal’s no longer accepts real estate). The Highly Qualified Professional Visa For Americans being recruited by Spanish companies for skilled positions, the Highly Qualified Professional (HQP) Visa provides a path tied to a specific job offer. It’s typically valid for two years and renewable, and it qualifies the holder for the Beckham Law tax regime. This is less common for traditional relocation but matters for executives and engineers being hired into Spanish operations. Choosing Among Them In practice, most Americans we work with end up on either the DNV (if working remotely) or the NLV (if retired or financially independent). The choice has significant tax implications down the line, particularly around eligibility for the Beckham Law, which we’ll cover next. The Spanish Tax System: What Americans Actually Pay This is where most pre-move planning gets serious. Spain taxes its tax residents on worldwide income — meaning your U.S. dividends, your rental income from a property in Texas, your capital gains from selling Apple stock, all of it can be subject to Spanish tax. The U.S.–Spain tax treaty and the Foreign Tax Credit prevent most cases of literal double taxation, but the interaction between the two systems creates real planning challenges. When You Become a Tax Resident Spain considers you a tax resident if any one of three things is true: you spend more than 183 days in Spain during a calendar year, your “center of economic interests” is in Spain (meaning your primary income or main assets are there), or your spouse and minor children habitually live in Spain (a rebuttable presumption). The 183-day rule is the most common trigger, and importantly, sporadic absences count toward the total unless you can prove tax residency in another country. This matters because Spanish tax residency is binary and applies to the full calendar year. If you arrive in Spain on July 1 and stay through year-end, you’ve spent 184 days there and you’re a tax resident for the entire year — including January through June, when you were still living in the U.S. Smart timing of the move can save substantial tax. We often recommend arriving after July 2 in a given year, which keeps you under the 183-day threshold for that year and pushes Spanish tax residency to year two. Income Tax Brackets Spanish income tax (IRPF) is progressive and combines a national portion with a regional portion that varies by autonomous community. For 2026, the combined general rates run roughly: Up to €12,450: about 19% €12,451 to €20,200: about 24% €20,201 to €35,200: about 30% €35,201 to €60,000: about 37% €60,001 to €300,000: about 45% Over €300,000: about 47% Investment income — dividends, interest, capital gains, and rental income from investments — is taxed on a separate “savings” schedule: Up to €6,000: 19% €6,001 to €50,000: 21% €50,001 to €200,000: 23% €200,001 to €300,000: 27% Over €300,000: 30% For most American expats earning between €40,000 and €80,000 per year, the effective Spanish tax rate is about 25–33%, which is comparable to or slightly lower than combined U.S. federal and state taxes for the same income. The pain points aren’t usually the standard rates — they’re the wealth tax, the lack of Roth recognition, and Modelo 720 reporting. The Beckham Law: A Major Opportunity Spain’s “Beckham Law” — named for the soccer player who was its early high-profile beneficiary — allows qualifying newcomers to be taxed as non-residents for up to six years, despite physically living in Spain. Under this regime, you pay a flat 24% on Spanish-source employment income up to €600,000 per year (47% on amounts above that), and your foreign income is generally exempt from Spanish taxation. For an American earning €100,000 per year on a Digital Nomad Visa with an employment contract, the Beckham Law saves roughly €10,000 annually compared to standard progressive rates — and the savings grow rapidly at higher income levels. For someone earning €250,000, the savings can exceed €40,000 per year. The Beckham Law has strict requirements. You generally must not have been a Spanish tax resident in the previous five years, you must move to Spain because of an employment contract or to take on a directorship, and — critically — you must elect into the regime within six months of registering with Spanish Social Security. Miss that six-month window and you cannot opt in later. We’ve seen this mistake destroy tens of thousands of euros of potential tax savings. The regime is available to W-2 employees and DNV holders with employment contracts. It is not available to self-employed autónomos in most circumstances, nor to Non-Lucrative Visa holders. This is why your visa choice has such significant tax implications. The Wealth Tax This is the tax that most surprises Americans. Spain’s wealth tax (Impuesto sobre el Patrimonio) is an annual levy on net worth as of December 31 each year. Spanish tax residents pay on their worldwide assets; non-residents only pay on Spanish-located assets. The structure includes a national tax-free allowance of €700,000 per person (which means €1.4 million for a married couple holding assets jointly), plus an additional €300,000 exemption for your primary residence in Spain. Above those thresholds, rates run progressively from 0.2% to 3.5%, depending on total assets and the autonomous community where you reside. Regional variation matters enormously here. Madrid and Andalucía effectively eliminate the wealth tax through 100% regional bonifications, though the national-level Solidarity Tax on Large Fortunes still applies above €3 million in those regions. Catalonia, by contrast, applies the tax in full. If wealth tax exposure is a serious concern for your situation, the autonomous community you choose to live in becomes a meaningful planning variable. There’s also a Solidarity Tax on Large Fortunes, introduced in 2023, that applies to net wealth above €3 million and adds an additional 1.7% to 3.5% on assets above that threshold. It coordinates with regional wealth tax relief to provide a national floor, so even residents of Madrid pay it on assets above €3 million. Roth IRAs in Spain: A Critical Issue Here is one of the most important things for Americans to understand before moving: Spain does not respect the tax-free status of Roth IRAs. Under U.S. law, qualified Roth IRA distributions are entirely tax-free, since contributions were made with after-tax dollars. Spain doesn’t see it that way. The Spanish tax authority (Hacienda) classifies Roth IRA distributions as investment income — specifically, as income from movable capital — and taxes them at savings rates. The taxable portion is generally the gain (the increase in value over your contributions), not the entire distribution, but this still represents a substantial loss of the Roth’s core benefit. A 2022 binding consultation (V1291-22) clarified this treatment, and the same ruling generally requires Roth IRAs to be reported on Modelo 720 and included in wealth tax calculations. The strategic implications are significant. If you have a large Roth IRA and you’re moving to Spain, you may want to consider taking distributions before establishing Spanish tax residency, while distributions are still tax-free in both countries. After becoming a tax resident, every Roth IRA distribution will likely face Spanish tax on the embedded gains. The same applies to any Roth conversions you might be considering — generally you want these completed before the move, not after. Traditional 401(k) and IRA distributions are treated more conventionally as pension or general income in Spain, and they’re taxable in both countries with foreign tax credits relieving most of the double taxation. The U.S.–Spain treaty was updated by a protocol that entered into force in November 2019, and it improves the treatment of cross-border pensions in several ways, though it does not solve the Roth issue. Capital Gains and Investment Income For Spanish tax residents, capital gains on the sale of most U.S. securities (like stocks held in a brokerage account) are taxable in Spain at savings rates of 19% to 30%. Under the U.S.–Spain treaty, gains on the sale of shares are generally taxed only in the country of residence, with limited exceptions for real estate and substantial shareholdings, so the planning here is relatively clean: if you sell while a U.S. resident, you owe U.S. tax; if you sell while a Spanish resident, you owe Spanish tax. This creates a major pre-move planning opportunity. If you have substantial unrealized gains in your taxable investment accounts, the year before your move is a powerful window. You can harvest gains at U.S. long-term capital gains rates — which top out at 23.8% including the Net Investment Income Tax — rather than at Spanish savings tax rates that run as high as 30% above €300,000 in gains. For a portfolio with $500,000 in unrealized long-term gains, the difference can be tens of thousands of dollars. This is one of the most common planning moves we recommend for clients moving to Spain with appreciated portfolios. The strategy isn’t always to harvest. If you’re moving to a non-Beckham regime and your overall income will push you into Spain’s higher capital gains brackets later, harvesting now may be valuable. If you have low income in Spain and modest gains, the Spanish tax may actually be lower than your U.S. rate. The right answer depends on your specific numbers — which is exactly the kind of cross-border modeling a fee-only planner is well-positioned to do without bias. The Foreign Earned Income Exclusion and Foreign Tax Credit U.S. citizens are taxed on worldwide income regardless of where they live, so you’ll continue filing U.S. returns from Spain. Two main mechanisms prevent literal double taxation. The Foreign Earned Income Exclusion (FEIE), claimed on Form 2555, allows you to exclude up to $130,000 of foreign earned income from U.S. taxation for the 2025 tax year (the limit adjusts for inflation each year). Qualifying requires either the bona fide residence test or the physical presence test (330 full days outside the U.S. in any 12-month period). Importantly, the FEIE only covers earned income — wages and self-employment income — not investment income. The Foreign Tax Credit (FTC), claimed on Form 1116, gives you a dollar-for-dollar credit against U.S. taxes for income taxes paid to Spain. Because Spanish rates often exceed U.S. rates at higher income levels, most expats earning above the FEIE threshold find the FTC works better. Excess credits can be carried back one year and forward ten years. The choice between FEIE and FTC has secondary effects worth understanding. The FEIE can disqualify you from making Roth IRA contributions if it pushes your taxable U.S. income low enough. The FTC preserves earned income for IRA contribution purposes. For families with college-age children, the FEIE can also affect the calculation of education credits. Reporting Obligations: Modelo 720 and FBAR Spanish tax residents must file Modelo 720 each year, declaring foreign accounts, securities, and real estate that exceed €50,000 in any of three categories. The form is informational, not a tax return, but penalties for non-filing have historically been severe (though the European Court of Justice forced Spain to substantially soften them in 2022). The filing window is January 1 through March 31 each year for the prior year’s data. On the U.S. side, you’ll continue to file: FBAR (FinCEN Form 114): required when total foreign accounts exceed $10,000 at any point during the year. Form 8938 (FATCA): required when foreign financial assets exceed $200,000 at year-end or $300,000 at any point during the year for single filers living abroad ($400,000/$600,000 for married filing jointly). Form 8621: required for any PFIC holdings — more on this below. Form 8833: to disclose treaty positions. The reporting load is real but manageable with the right preparer. What gets people in trouble isn’t usually the difficulty of any single form — it’s not knowing the forms exist. Investments: What to Do Before You Become a Spanish Tax Resident This is the single most consequential financial planning area for Americans moving to Spain, and the area where pre-move action matters most. Once you’re a Spanish tax resident, your options narrow considerably. The window before that happens is when most of the high-leverage decisions get made. The Brokerage Account Problem A wave of U.S. brokerage firms — including Vanguard, Fidelity, Morgan Stanley, Merrill Lynch, Edward Jones, Ameriprise, TIAA, USAA, and others — have been restricting or closing accounts of U.S. citizens who update their address to a foreign country. The pace accelerated sharply in 2024 and 2025 as firms tightened compliance with anti-money-laundering and FATCA-related requirements. Some firms close accounts outright; others restrict trading to liquidating positions only; some allow continued holdings but block new purchases. The practical implications for someone planning to move to Spain are: Don’t update your address until you have a plan. Once your firm sees a Spanish address, you may have 30 to 60 days to make decisions under significant time pressure. Identify expat-friendly custodians in advance. Charles Schwab International and Interactive Brokers continue to serve U.S. expats in Spain with relatively few restrictions, and a handful of independent advisory firms maintain relationships with custodians who will hold accounts for U.S. citizens abroad — typically when those accounts are managed by the advisory firm rather than self-directed. Transfer assets in-kind, don’t liquidate. If you’re forced to move accounts, transferring securities directly between custodians avoids creating a tax event. Liquidating into cash can trigger massive unintended capital gains. We spend considerable time at AIO Financial helping clients structure their accounts to remain compliant and accessible from abroad. The best time to do this work is before the move. Why Local European Brokerages Are a Trap for Americans The natural instinct, once you’ve moved to Spain, is to open a Spanish or European brokerage account and invest locally. For non-Americans, this is fine. For U.S. citizens, it’s a tax catastrophe — because of the Passive Foreign Investment Company (PFIC) rules. Under U.S. tax law, virtually any non-U.S. pooled investment vehicle — every European mutual fund, every UCITS ETF, every European-domiciled index fund — is classified as a PFIC. The IRS designed PFIC rules to discourage Americans from investing in foreign funds that the IRS cannot easily audit, and the punishment is severe: PFICs are taxed at the highest ordinary income rates (currently up to 37%) on gains, with interest charges layered on top, and require an annual Form 8621 filing that can take a tax preparer several hours per fund to complete. There’s a Qualified Electing Fund (QEF) election that can avoid the worst of these rules, but it requires the foreign fund to provide an annual PFIC statement with very specific information. Almost no European fund managers produce these for retail investors, so QEF elections are theoretically available but practically impossible. The bottom line is straightforward: as a U.S. citizen living in Spain, you generally need to invest through a U.S. brokerage in U.S.-domiciled funds and ETFs. Buying European funds — even excellent, low-cost European index funds — turns a clean financial picture into a tax disaster. There’s a complicating wrinkle: EU MiFID II regulations restrict EU-resident investors from buying many U.S.-domiciled ETFs, because U.S. fund providers haven’t produced the EU-required Key Information Documents. Most U.S. expats in Europe end up holding individual stocks, ETFs purchased through expat-friendly U.S. brokerages, and pre-existing fund positions. Some use options strategies or structured workarounds. Working with a cross-border advisor who understands which products remain accessible matters here. Pre-Move Investment Moves to Consider Twelve to eighteen months before your move, the following are typically worth analyzing: Harvesting long-term capital gains. As discussed above, U.S. long-term gains rates often beat Spanish savings rates, and once you’re a Spanish resident, every sale potentially triggers Spanish tax. Strategically selling and rebuying appreciated positions in your final U.S. year can lock in U.S. tax treatment. Roth conversions. If you have meaningful traditional IRA balances and you’re not in a high U.S. tax bracket, completing Roth conversions before the move means the conversion is taxed at U.S. rates only. After the move, conversions get more complicated (and the resulting Roth doesn’t get U.S.-style tax-free treatment in Spain anyway). Roth distributions. For older clients with substantial Roth balances who plan to draw on them in retirement, taking distributions before becoming a Spanish tax resident captures the full Roth benefit. Once in Spain, the gain portion of every distribution is taxable. HSA decisions. Health Savings Accounts are not recognized by Spain. The income inside them is potentially taxable annually for Spanish tax residents. Some clients draw down HSAs before the move; others maintain them with the understanding that ongoing reporting and tax will apply. 529 plans. Similar issues. 529 plans aren’t recognized as tax-advantaged in Spain, and depending on the structure, may create ongoing Spanish tax liability. Drawing down 529s for U.S. educational use before the move, or restructuring them, is often part of the plan. Real estate decisions. Selling a U.S. primary residence before the move keeps the Section 121 exclusion ($250,000 single / $500,000 married) cleanly available under U.S. rules. Selling after the move adds Spanish tax considerations and can complicate the exclusion. Renting out the U.S. home while abroad creates ongoing reporting in both countries but can be the right answer for those who plan to return. Trust and estate review. U.S. revocable living trusts are not recognized as transparent in Spain — Spanish tax authorities may treat them as opaque foreign entities, which can create unexpected tax consequences. Estate plans drafted under U.S. assumptions often need substantial revision before a move. Should You Keep Investments in the U.S. or Move Them Abroad? For almost every American citizen moving to Spain, the answer is: keep your investments in the U.S. The combination of PFIC rules, EU MiFID II restrictions on U.S. ETFs, and the comparatively higher costs and lower transparency of European retail investing means that a U.S.-domiciled portfolio held at an expat-friendly U.S. brokerage is almost always the right structure. The exception is if you renounce U.S. citizenship — but that’s a separate, much larger conversation. What changes is what you hold and how you manage it. U.S.-domiciled ETFs and individual stocks remain the foundation. You may need to adjust around currency exposure (more on this below), tax-efficiency rules that differ between the two countries, and the loss of access to certain U.S. mutual funds that don’t allow non-resident purchases. Asset location — what you hold in Roth versus traditional versus taxable accounts — also looks different through a cross-border lens. Currency Considerations One question we get often: should you convert to euros once you move? The honest answer is “it depends on your time horizon and liabilities.” Most retirees and long-term residents in Spain end up with euro-denominated living expenses but dollar-denominated investments. Over time, this creates currency exposure: a 10% drop in the dollar means your investment portfolio buys 10% less in Spain. There are a few approaches we use with clients: Hold a euro cash reserve sufficient to cover 1–2 years of living expenses. This protects against short-term currency movements forcing investment sales at bad prices. Don’t try to time currency markets. Strategic currency hedging at the portfolio level is rarely worth the cost for individual investors. For larger portfolios, consider modest direct euro exposure through ETFs that hold European equities or international developed-market funds. Don’t overdo it — global diversification is good; concentrated currency bets are not. Moving Cash: How to Actually Get Money to Spain Getting funds across the Atlantic has gotten easier in recent years but still has friction points worth understanding. Wire Transfers vs. Money Service Providers Traditional bank wires from a U.S. bank to a Spanish bank work but are typically expensive — fees commonly run $25–$50 per outbound wire from the U.S. side, plus a poor exchange rate that often costs another 1–3% of the amount transferred. For a $100,000 transfer, that’s potentially $3,000+ in spread costs. Specialized providers like Wise (formerly TransferWise), OFX, and Revolut typically offer mid-market exchange rates with much lower fees, often under 0.5% all-in. For larger transfers, a foreign exchange broker can negotiate even better rates, sometimes with a forward contract that locks in the exchange rate for a specific future date — useful when you’re closing on a Spanish property and want to know exactly how many dollars the euro purchase price will cost. For most cross-Atlantic transfers under $250,000, Wise is the simplest and lowest-cost option. Above that, dedicated FX brokers start to make sense. Spanish Bank Accounts You’ll need a Spanish bank account for daily living. The traditional banks (CaixaBank, BBVA, Santander) all offer non-resident accounts you can open before establishing residency, though increasingly they want to see your NIE (Spanish foreigner identification number) or your visa. Newer digital banks like N26 and Revolut are popular with expats for their lower fees and English-language interfaces, though some Spanish landlords and employers still prefer traditional banks. A common approach: open a basic non-resident account at a major Spanish bank for housing transactions and government payments, plus a Wise multicurrency account for receiving USD income and converting to EUR efficiently. Reporting Large Transfers Both U.S. and Spanish authorities track large cross-border transfers. On the U.S. side, transfers over $10,000 are reported automatically by your bank to FinCEN. On the Spanish side, banks report incoming international transfers to the Banco de España and tax authorities. None of this is illegal or problematic — but if you’re moving $400,000 to buy a house in Valencia, expect both sides to know, and don’t structure transfers in ways that look like you’re trying to avoid reporting (which is itself a U.S. federal crime). Cash Buffer for the First Year We typically recommend clients have at least six months — preferably twelve months — of Spanish living expenses available in liquid form before the move, in addition to their long-term investment portfolio. The first year in Spain comes with surprise costs: temporary housing, deposits, immigration fees, legal and tax advisor fees, furniture, car purchases, healthcare deposits. Having a cash buffer means none of this requires selling investments at a bad time or running up debt at unfavorable rates. Healthcare, Insurance, and Social Security Spain has one of the better healthcare systems in the developed world, but accessing it as a new arrival requires planning. Most visa categories require private health insurance during the application process and typically through the first year of residency. Standard policies from companies like Adeslas, Sanitas, and Asisa run €60–€150 per month per person depending on age and coverage level. After establishing residency and (for those working in Spain) contributing to Spanish Social Security, you become eligible for the public system, which is generally excellent. For Americans on Medicare, Medicare does not cover care received in Spain. Some retirees maintain Medicare and pay the Part B premiums in case they return to the U.S.; others let it lapse. Reactivation comes with late-enrollment penalties, so this decision deserves careful thought before it’s made. U.S. Social Security retirement benefits continue to be paid to U.S. citizens living in Spain, and the U.S.–Spain Totalization Agreement helps prevent dual social security taxation for many work situations. Working in Spain also generates Spanish social security credits that may eventually qualify you for Spanish retirement benefits, though qualification typically requires fifteen or more years of contributions. Estate Planning Across Borders This is the area most often deferred — and most often regretted. U.S. estate plans drafted assuming U.S. residence rarely work cleanly in Spain. Spain has its own inheritance and gift tax (Impuesto sobre Sucesiones y Donaciones) that applies to Spanish residents and to inheritances of Spanish-located assets. National rates run from 7.65% to 34%, with multipliers based on the relationship between the deceased and the beneficiary. Autonomous communities have wide latitude to set their own rates and bonifications, so effective rates vary enormously: in Madrid, Andalucía, and several other regions, close family members pay almost nothing; in others, rates approach the national maximum. Spanish forced heirship rules also differ from U.S. rules. Spain reserves a legitimate portion of an estate for certain heirs (typically children), which can override testamentary wishes expressed in a U.S. will. EU Regulation 650/2012 allows you to elect U.S. (or your nationality’s) law to govern your succession, but this election generally must be made explicitly in your will and is not automatic. Revocable living trusts, the workhorse of U.S. estate planning, are not transparent in Spain. The Spanish tax authority may treat the trust as a separate opaque entity, which can create unexpected income tax during life and complicate inheritance treatment at death. Many cross-border families need to revise or replace their trust structure before the move. Practical recommendations: consult a Spanish abogado experienced in cross-border estate planning before the move. Have a Spanish will (separate from your U.S. will) covering Spanish-located assets. Make explicit choice-of-law elections under EU Regulation 650/2012. Review beneficiary designations on all U.S. accounts to ensure they still make sense. Lifestyle Costs: What Spain Actually Costs in 2026 A rough framework for Spanish living costs in 2026, by region: Mid-sized cities (Valencia, Granada, Málaga, Seville, Zaragoza): A comfortable lifestyle for a single person runs €1,800–€2,500 per month including rent for a one-bedroom in a desirable neighborhood. A couple typically lives well on €3,000–€4,500 per month. Madrid and Barcelona: Add 30–50% to the above. A nice one-bedroom in central Madrid runs €1,400–€2,000 per month; in Barcelona, €1,500–€2,200. Total monthly costs for a single person comfortably range €2,800–€4,000. Coastal premium areas (Marbella, Ibiza, parts of Mallorca): Closer to U.S. coastal city costs, especially in summer months. Expect €4,000+ monthly for comfortable single living, often €6,000+ for couples. Rural and smaller towns: Substantially lower. Many Americans report living comfortably in Spanish villages or small cities for €1,500–€2,000 monthly per person, including rent. These figures cover housing, food, utilities, transport, basic entertainment, and private health insurance. They don’t include big-ticket items like a car purchase, international travel, or major medical events. A Practical Pre-Move Timeline For a hypothetical move twelve to eighteen months in the future, here’s the timeline we generally recommend: T-18 to T-12 months: Strategic planning. Engage a U.S.-side cross-border financial planner and a Spanish abogado/tax specialist. Decide on visa pathway. Begin tax-projection modeling. Identify which U.S. accounts will move and which custodians can serve you abroad. Begin Spanish language study if you haven’t already. T-12 to T-9 months: Big financial moves. If indicated, complete Roth conversions. Begin strategic gain harvesting in taxable accounts. Review 529 and HSA balances for pre-move decisions. Decide on U.S. real estate (sell, rent, or hold). Update estate documents. T-9 to T-6 months: Visa application. Gather documents, get FBI background check apostilled, prepare income documentation, file the visa application. (Application processing typically takes 4–5 months.) T-6 to T-3 months: Logistics. Arrange international moving company. Begin planning what to ship versus sell versus store. Open expat-friendly U.S. brokerage account if needed. Open Spanish non-resident bank account if possible. Identify Spanish housing for the first 3–6 months. T-3 months to move date: Execution. Final tax planning moves. Cancel U.S. utilities, services, insurance. Notify employer if working remotely. Confirm all Spanish appointments (NIE, padrón, visa pickup). Time the actual move date for tax efficiency — generally after July 2 in any given calendar year if circumstances permit. T-0 to T+6 months in Spain: Settling in. Register with local padrón. Apply for Tarjeta de Identidad de Extranjero (TIE). Set up Spanish utilities, internet, healthcare. Critically: file Beckham Law election within 6 months of Social Security registration if eligible. Begin Spanish tax registration with AEAT. T+12 months: First Spanish tax return. File first IRPF return for the partial year (if applicable). Review and adjust ongoing tax strategy based on actual income realized. How AIO Financial Works With Cross-Border Clients At AIO Financial, our work with Americans moving to Spain is fundamentally about reducing the cost of bad surprises. We are a fee-only fiduciary firm — meaning we receive no commissions, no kickbacks, no revenue from any product we recommend. Our clients pay us directly, and we work only for them. That structure matters especially for international moves, where the financial services industry’s commission-based incentives often push expats into expensive insurance products and PFIC-laden offshore structures that primarily benefit the salesperson. Our typical engagement with a Spain-bound client involves an initial deep planning phase eight to twelve months before the move, then transition support during the move itself, then ongoing investment management and annual planning review once settled. We coordinate with Spanish tax counsel and U.S. expat tax preparers — we don’t replace them, but we make sure all the pieces fit together. We help clients maintain compliant U.S. brokerage relationships from abroad through our institutional arrangements. We don’t claim to be everything. We’re not Spanish lawyers or accountants. We don’t handle Spanish tax filings ourselves. Spain’s gestores and Spanish tax advisors handle that side of the picture. Our role is the U.S.-side planning and the cross-border coordination — making sure the two systems work together rather than against each other for our clients. The Bottom Line Moving to Spain can be one of the best financial and lifestyle decisions an American family makes. It can also be one of the most expensive, depending on how the planning goes. The difference is rarely about how much money you have — it’s about how much advance planning you do. The tax rates aren’t usually the killer. Spain isn’t dramatically more expensive than the U.S. on income tax for most middle-income families. What costs people money is the avoidable mistakes: missing the Beckham Law deadline, holding the wrong type of investments, triggering U.S. capital gains in Spain when they could have been harvested at home, getting blindsided by Modelo 720 reporting, ending up in a high-wealth-tax region without realizing it. Almost all of these are preventable. The work to prevent them mostly happens twelve to eighteen months before the plane takes off, not after. If you’re seriously considering Spain, the time to start the financial planning conversation is now. AIO Financial is a fee-only fiduciary financial planning firm registered with the SEC, headquartered in Tucson, Arizona, and serving clients virtually across the United States and abroad. We specialize in expat financial planning, sustainable and impact investing, retirement planning, and tax-aware investment management. We earn no commissions, sell no products, and are compensated only by our clients. To discuss your situation, visit aiofinancial.com or contact us at 520-325-0769. This guide is for educational purposes only and is not legal, tax, or investment advice. Tax laws and visa rules change frequently. The figures, thresholds, and rates cited reflect our understanding as of early 2026 and are subject to change. Please consult qualified U.S. and Spanish professionals about your specific situation before making cross-border financial or relocation decisions.

Think PFIC is only a pediatric disease? Think again. Progressive Familial Intrahepatic Cholestasis (PFIC) was long considered a condition exclusive to children. However, breakthroughs in genomic sequencing are revealing a hidden population: adults with "unexplained" cholestasis who are actually living with undiagnosed PFIC variants. Early identification is the difference between manageable care and irreversible liver damage. In this interview episode Dr. Aparna Goel, Stanford School of Medicine, and Dr. Laura Bull, UC San Francisco, break down the adult phenotype of PFIC and how clinicians can close the diagnostic gap. What You'll Hear In This Episode: The Adult Phenotype: Why adult cases often present as "indolent" or mild compared to the severe jaundice seen in infants. Diagnostic Red Flags: When to move beyond standard autoimmune panels and look for genetic markers. Genetic Testing 101: A comparison of targeted gene panels vs. whole exome sequencing for the most efficient diagnosis. The Power of a Name: How a specific PFIC diagnosis changes everything—from family counseling to starting life-altering IBAT inhibitors.

For those moving to America, knowing what needs to happen before becoming a US tax resident can save you a lot of money. The opportunity can be enormous, but so can the tax mistakes. From foreign mutual funds that trigger punitive PFIC taxation, to offshore companies that become highly inefficient in the US, to pensions, trusts, and inheritances that create unexpected reporting obligations, many expats arrive without realising how quickly their existing financial setup can become problematic once they enter the US tax system.  Richard Taylor – dual UK/US citizen and Chartered Financial Planner – is joined by David Gershel – international tax attorney and Partner at Berkowitz, Trager & Trager LLC – to discuss why pre-immigration planning is one of the most overlooked but valuable parts of the moving process.  Drawing on real client examples, they explain how structures that work perfectly well abroad can become expensive liabilities in America, why California and other states can create tax problems beyond the federal system, and how failing to plan early can leave expats dealing with costly cleanup work years later.  In this episode of Expat Wealth, Richard and David discuss why foreign investments and pensions often create problems for new US residents, how offshore trusts and companies can trigger unintended tax consequences, what inheritance and reporting traps many expats miss, and why working with experienced US tax help and international wealth professionals before your move can save significant money and stress down the line.  –  Expat Wealth is supported by Plan First Wealth. Plan First Wealth is a Registered Investment Advisor serving fellow expatriates and immigrants living across the US on matters such as retirement planning, investment management, tax planning and non-US asset management.  https://planfirstwealth.com/  –  Expat Wealth 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. 

Shray sits down with Deepak Shenoy from Capitalmind to unpack the real playbook for NRIs thinking about investing in India — the taxes, the paperwork, the returns, and the traps nobody warns you about. What we uncover: The 3 types of NRIs who should invest in India — and the ones who absolutely shouldn't. Why patriotism and FOMO are the worst investment strategies. The real return math: 12% in rupees, ~8% in dollars after currency depreciation — and why falling inflation could change this equation entirely. Stocks vs. mutual funds vs. real estate: Why your passport decides your investment vehicle. UAE and Singapore NRIs get tax-free mutual fund gains; US and UK residents face PFIC nightmares. The paperwork horror: Why 5% of your portfolio in India creates more admin than the other 95% abroad — and why Deepak respects any NRI who's actually opened a Demat account. The "famous stocks" trap: Why buying Indigo, Swiggy, or Jubilant from abroad without local context is a recipe for pain. Great brands ≠ great investments. Moving back math: ₹2L/month puts you in India's top 1%. $500K in fixed income could fund your entire re-entry. And why you still shouldn't bring everything back. Deepak breaks down the Doordash minimum wage vs. Indian purchasing power, why small caps hold India's real growth story, and why NRI investing success is measured in rupees — not dollars. Chapters: 0:00 - Not every NRI should invest in India 1:36 - Who is this conversation really for? 3:54 - The 3 types of people who SHOULD invest in India 6:34 - You have family & money sitting idle in India 7:19 - You know you're coming back someday 11:44 - The worst reason to invest in India 18:16 - Stocks, mutual funds, real estate — where to put your money? 22:07 - Your 12% return is actually 8% (here's why) 29:43 - Is Indian real estate worth it for NRIs? 36:57 - The paperwork nightmare no one warns you about 37:26 - Where you live changes everything 38:09 - UAE & Singapore NRIs — this is your tax cheat code 40:07 - Why US & UK NRIs should avoid Indian mutual funds 45:25 - Why buying Indian stocks from abroad is risky 51:44 - Great company. Terrible investment. Here's the difference 1:03:15 - Should you move more money to India as you plan to return? 1:09:26 - What does winning actually look like? 1:16:29 - Invest with your head, not your passport

Moving to the US is an exciting step, but for Indians making that move, the financial complexity can be significant. From Demat accounts and Provident Funds to ULIPs, the assets that made perfect sense back home can quickly become compliance headaches, tax traps, and costly surprises in America. The good news is that with the right guidance – ideally before you arrive – most of these problems are entirely avoidable.    In this episode of Expat Wealth, Richard Taylor – dual UK/US citizen and Chartered Financial Planner – is joined by Manasa Nadig, Enrolled Agent and owner of MN Tax and Business Services, and co-host of the International Money Cafe podcast. Together, they walk through the most common Indian financial assets held by expats in America, what US reporting rules apply to each, and why pre-immigration planning can make the difference between a smooth transition and years of non-compliance.  Richard and Manasa discuss:    The four main Indian asset categories that matter for US tax purposes: Bank accounts, Demat accounts, Provident Funds, and insurance policies each carry different reporting requirements under FATCA and FBAR. Manasa breaks down what each one is, how it maps to more familiar US equivalents, and why simply not knowing about them is no defence with the IRS.    Why Demat accounts and ULIPs may trigger the PFIC problem: Mutual funds and unit-linked insurance policies held in India are typically classified as Passive Foreign Investment Companies under US tax law, bringing punitive tax treatment and complex annual reporting. Richard and Manasa explore why these are so hard to unwind once you are stateside, and why catching people before they arrive is so much more valuable than cleaning up afterwards.    Inheritances, gifts, and real estate – the traps people miss: From inherited property in Mumbai to gold jewellery gifted by grandparents, assets crossing borders often trigger Form 3520 reporting requirements that catch even well-intentioned expats off guard.     Richard and Manasa explain what needs to be reported, what the actual tax consequences are, and why failing to report can be far more costly than the assets themselves.    --    Expat Wealth is supported by Plan First Wealth. Plan First Wealth is a Registered Investment Advisor serving fellow expatriates and immigrants living across the US on matters such as retirement planning, investment management, tax planning and non-US asset management.  https://planfirstwealth.com/    --    Expat Wealth 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. 

Quand on s'expatrie aux États-Unis, on s'attend à devoir changer de système de santé, de culture ou de vocabulaire… mais rarement à devoir devenir expert·e en fiscalité internationale !Dans cet épisode, Jean-Philippe Saurat, expert-comptable et fiscaliste, revient dans French Expat pour démystifier la déclaration fiscale franco-américaine.On parle de l'imposition mondiale des revenus, des formulaires FBAR, 8938 ou PFIC, de l'assurance-vie française vue par l'IRS, et de toutes ces petites choses qui peuvent avoir de grandes conséquences si on les néglige.Un épisode concret, clair et sans jargon — pour enfin comprendre comment déclarer sereinement ses impôts quand on vit entre la France et les États-Unis

In this episode of Liver Lineup: Updates & Unfiltered Insights, host Nancy Reau, MD, sits down with Kris Kowdley, MD, to discuss evolving approaches in cholestatic liver disease, with a particular focus on primary biliary cholangitis (PBC).Key episode timestamps:0:00:00 – Guest intro & evolution of PBC therapy0:07:34 – Redefining biochemical response & earlier assessment0:16:26 – OCA withdrawal & positioning PPARs/fibrates0:22:16 – Diagnosing AMA‑negative PBC0:25:58 – Genetic cholestasis panels & PFIC spectrum0:29:45 – Symptom burden, pruritus, & IBAT inhibitors0:35:17 – Bone health & closing remarks

How to Retire in PortugalPicture it: retiring fabulously in Portugal with LGBTQ+ protections, world-class healthcare, and the freedom to split time between Europe and the U.S.—without uprooting your life today. In Queer Money® episode 613, we sit down with Pedro Lino, CEO of Optimize Investment Partners, to unpack the Portugal Golden Opportunities Fund—a SEC-registered, PFIC-compliant mutual fund designed to qualify investors for Portugal's Golden Visa (residency now, citizenship later). We cover why a Golden Visa can be smart “life-hedging” in uncertain times, how the fund works (stocks/bonds, no real estate), what's changing in Europe, using self-directed IRAs, costs, timelines, and how one investment can include your spouse, kids, and even parents through family reunification.Whether your dream is six months in Lisbon and six months stateside, a second passport for your kids' future, or a values-aligned Plan B if U.S. politics keeps fraying your nerves, this episode gives you the details to decide with confidence.TakeawaysA Golden Visa is optionality: live/work/travel in the EU now or later—without leaving the U.S. immediately.Portugal is consistently LGBTQ+ friendly, with significantly lower healthcare costs and robust protections.The current path is via eligible investment funds (no real estate); fund must meet strict criteria (≥60% PT companies, no real estate, long-only, five-year availability).Self-directed IRAs can be used; look for SEC-registered and PFIC-compliant structures to keep U.S. tax/reporting clean.One qualifying investment can include spouse, kids, and parents via family reunification, creating a multi-generational Plan B.Chapters00:00 – Dream setup & why a Plan B now01:22 – What a Golden Visa actually gives you (residency → citizenship)03:18 – You don't have to move today: optionality for LGBTQ+ families05:02 – Why Portugal for LGBTQ+ safety, community & healthcare07:10 – Real-estate option removed: what changed and why funds remain10:12 – Inside the Golden Opportunities Fund (eligibility rules, asset mix)13:15 – Returns, risk, and diversification vs. buying a single property16:02 – Using self-directed IRAs; SEC & PFIC compliance explained19:04 – Demand, timelines, and potential policy shifts to watch22:31 – Costs, EUR/USD realities & creative ways families reach €500K26:05 – Family reunification: who can be included under one application28:40 – Downturn strategy: dividend-rich Portuguese market & bonds31:12 – What Optimize handles vs. what U.S. custodians/lawyers handle34:20 – Wrap-up & how to send us follow-up questionsDownload your free Happy Gay Retirement CalculatorMentioned in this episode:Get Your Portugal Golden Visa Faster Here!Want a European passport with access to living in nearly any European country? Just click the link below to find out how. Get Your Portugal Golden Visa Here!Get Your Portugal Golden Visa Here!

Welcome to the one hundred fifty-eighth episode of #ExpatChat, where we explore the latest tax, investment, and financial issues affecting #AustralianExpats. In this episode, Atlas Wealth Group's Managing Director - APAC, James Ridley is joined by guest co-host Martin Jack, one of our specialist financial planners based on the Gold Coast. Together, they unpack some of the most common and costly financial mistakes Australian expats make when moving overseas — and how to avoid them. Drawing from real-life questions submitted by members of the Australian Expat Facebook Group, James and Martin tackle key topics including: • The biggest financial mistake expats make before leaving Australia – and why preparation is everything. • The “PFIC trap” – why Australian ETFs and managed funds can trigger hefty US tax bills. • How restricted stock units (RSUs) are taxed in the US — and what high-income earners need to watch for. • Property ownership as a non-resident – should you keep or sell before moving abroad? • Planning for retirement when you don't know where you'll settle – managing tax and currency risks across borders. Packed with practical insights that every Australian abroad should know, this episode is a must-listen for anyone planning their next move or currently living overseas. Links discussed in this episode: • Upcoming Seminars & Webinars – atlaswealth.com/events • Facebook Group – Join the Australian Expat Financial Forum: facebook.com/groups/AustralianExpatFinancialForum • Ask Atlas – Submit your questions for the podcast: atlaswealth.com/news-media/australian-expat-podcast • Expat Mortgage Podcast – atlaswealth.com/news-media/australian-expat-mortgage-podcast • Weekly Recap Podcast – atlaswealth.com/news-media/atlas-weekly-recap-podcast If you enjoy the content, let us know by giving the episode a thumbs up and subscribing. Feel free to share your feedback or questions in the comments below. About Atlas Wealth Group: Atlas Wealth Group was established to meet the growing demand from Australian expats for professional financial guidance. We specialise in providing tax, financial planning, wealth management, and mortgage services to Australian expats around the world. Whether you're based in Asia, the Middle East, Europe, or the Americas, our team has the expertise to help you manage your global financial journey. To learn more, visit www.atlaswealth.com Connect with us: Facebook: www.facebook.com/atlaswealthmgmt LinkedIn: www.linkedin.com/company/atlas-wealth-management Twitter: www.twitter.com/atlaswealthmgmt Instagram: www.instagram.com/atlaswealthgroup

Should an American living in Canada hold a TFSA—or avoid it? Ask 10 accountants and you might get 15 different answers. That's why this episode of Snowbirds Expat Radio brings in cross-border tax expert Christa Walkden from 49th Parallel Tax.With nearly 30 years of experience in U.S. and Canadian taxation, Christa breaks down the complexities around Tax-Free Savings Accounts (TFSAs) for U.S. citizens in Canada. She explains the spectrum of filing positions, from the most conservative (treating the TFSA as a foreign trust with Form 3520 filings) to more practical approaches that rely on disclosure and income reporting.Listeners will also hear:Why the IRS hasn't clarified the TFSA's status—and what that means for you.How Canadian mutual funds inside a TFSA create extra problems under U.S. PFIC rules.The pitfalls of transferring TFSAs into U.S.-owned firms (like capital gains surprises).Why collaboration between advisors, accountants, and immigration lawyers is critical.When it actually makes sense for Americans to keep a TFSA, depending on their other income and foreign tax credits.Christa and Gerry also touch on the hope that a future treaty update could treat TFSAs the same way Canada treats Roth IRAs—finally bringing clarity for cross-border families.Resources

Richard and James are back with more cautionary financial tales. Richard Taylor, founder of Plan First Wealth, recently spoke to a connection who “had done a bit of research, learned that mutual funds were a problem, hadn't learned what PFICs were, and switched out of a mutual fund into an investment trust... thinking he'd dodged the problem, but in fact he'd gone from one PFIC to another.” What was the result? And why is it such a problem? You'll find out in this episode of From The Trenches.Richard and James share real-world stories that highlight how easy it is to fall into tax traps when dealing with cross-border investments, especially for UK expats living in the US. You'll hear how well-meaning financial decisions can backfire without the right context or professional advice, particularly around things like ISAs, investment trusts, PFIC reporting, and the long-term implications of missing forms like 3520 and 8621.Plus, expert advice and insight into retirement readiness. Richard and James explores what changes when you stop earning, why even successful DIY investors often hand over the reins, and how complex planning becomes when you're managing assets across two tax systems. If you're a Brit in America navigating retirement, tax compliance, or residency decisions, this episode will help you avoid costly mistakes, understand the emotional weight of retirement planning, and see the real value of cross-border financial advice.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.

The market has rebounded from a rough April, but that period caused significant emotional stress for both clients and advisors. In these market downturns it's crucial to put your emotions to one side and stick to your plan. What's happened in June? And we're only a few days into July but so much has happened there too; Richard Taylor and James Boyle go back into the trenches to unpack it all. Plus, a few cautionary tales: Richard has a friend who – for years – has been constantly predicting a catastrophic market crash. As a result his investment plan is needlessly conservative. Another acquaintance tells of his experience with the 2008 market crash; panic selling resulted in the loss of huge returns over the decades. Richard and James discuss another investor who made a common mistake, siloing US and UK tax advisors and not giving his advisors on either side the full picture. Despite investing in cross-border advice from one of the better-known tax advisory firms in the business, the client might now face PFIC tax issues in the hundreds of thousands. The bottom line: ensure you have the right advisors and they are working together. The unique workings of the US tax system and its state-based rules are confusing for expats – make sure you get the right advice. 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.

This educational program, hosted by Patrick McKiernan, MD, Pediatric Hepatologist at Birmingham Children's Hospital NHS Foundation Trust and Nadia Ovchinsky, MD, Professor of Medicine at NYU Grossman School of Medicine discuss the recently published guidance on best practices to diagnose, treat, and monitor patients with PFIC. It also explains why the new guidance recommends the early use of IBAT inhibitors in patients suspected of having progressive familial intrahepatic cholestasis (PFIC).PFIC encompasses a spectrum of autosomal recessive disorders characterized by impaired bile flow (cholestasis) due to defects in biliary epithelial transporters. These rare genetic conditions typically manifest in infancy or early childhood, leading to severe liver dysfunction and potentially life-threatening complications if left untreated. Common early symptoms observed in children with PFIC are jaundice, pruritus, elevated serum bile acid (SBA) values, malabsorption, and failure to thrive. PFIC can be a debilitating condition that significantly impacts the quality of life and can result in end-stage liver disease. As such, early detection and effective intervention are imperative for the prevention of disease progression. Unfortunately, there are no relevant guidelines based on newly published research to help healthcare providers manage patients with PFIC. However, a recent opinion paper by leading experts in the management of PFIC provides evidence-based guidance on this subject and was recently published in JHEP Reports. This educational program is made possible by an unrestricted grant from Ipsen.

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.

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.­

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

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

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