The Essential Tax Podcast with Mishkin Santa, Episode 16

In this episode of The Essential Tax Podcast,  Mishkin Santa, J.D., LL.M, talks about potential U.S. tax changes following the 2024 election. He is a Principal at The Wolf Group, focusing on international tax services such as offshore disclosure, pre-immigration planning, and more, drawing on his experience as a former IRS Attorney.

Tune in for these key takeaways:

* Post-Election Tax Implications: Mishkin Santa highlights the 2024 Republican "red sweep" as pivotal for future tax changes.

* Historical Context and TCJA Expiration: Mishkin Santa warns of a 2025 "tax cliff" as key TCJA provisions near expiration.

* Proposed Corporate Tax Adjustments: Mishkin Santa discusses reducing corporate tax rates and adding a 15% rate for manufacturers.

* Individual Tax Proposals: Mishkin Santa mentions tax cuts, SALT cap changes, and exemptions for certain groups.

* International Tax Considerations: Mishkin Santa suggests simplifying taxes for expatriates instead of major overhauls.

Further resources:

 * Tax Cuts and Jobs Act of 2017:

 *  * https://www.law.cornell.edu/wex/tax_cuts_and_jobs_act_of_2017_(tcja)

 *  * https://taxpolicycenter.org/briefing-book/how-did-tcja-change-standard-deduction-and-itemized-deductions

 * SALT Cap: https://taxfoundation.org/taxedu/glossary/salt-deduction

 * Home Mortgage Interest Deduction and Limitation: https://www.nerdwallet.com/article/taxes/mortgage-interest-rate-deduction

 * Qualified Business Income Deduction (IRC 199A): https://www.journalofaccountancy.com/issues/2018/may/sec-199a-deduction-for-qualified-business-income.html

 * The Byrd Rule: https://en.wikipedia.org/wiki/Reconciliation_(United_States_Congress)

 * John Thune: https://en.wikipedia.org/wiki/John_Thune

 * Mike Crapo: https://en.wikipedia.org/wiki/Mike_Crapo

 * Mike Johnson: https://en.wikipedia.org/wiki/Mike_Johnson

 * Jason Smith: https://en.wikipedia.org/wiki/Jason_Smith_(American_politician)

 * Exempting Tip Income: https://taxpolicycenter.org/taxvox/exempting-tips-federal-income-tax-would-benefit-very-few-workers

 * Exempting Income Tax for Firefighters, Police Officers, Veterans, Active Duty Military: https://budgetlab.yale.edu/news/241028/no-tax-police-officers-firefighters-veterans-and-active-duty-military-basic-background

 * Automobile Interest Deduction: https://taxpolicycenter.org/fiscal-facts/how-much-would-auto-loan-interest-deduction-cost

 * TCJA Extension Cost: https://www.crfb.org/blogs/tcja-extension-could-add-4-5-trillion-deficits

 * President Elect Trump Campaign Tax Proposals: https://taxfoundation.org/research/all/federal/donald-trump-tax-plan-2024/

 * Tariffs and Sovereign Wealth Fund:

 *  * https://www.forbes.com/sites/antoniopequenoiv/2024/09/05/trump-proposes-sovereign-wealth-fund-for-us-what-to-know-about-the-state-owned-budget/

 *  * https://taxpolicycenter.org/taxvox/could-tariffs-help-trump-keep-his-promises

 * Death Tax Repeal Act of 2023: https://www.congress.gov/bill/118th-congress/senate-bill/1108

 * 2026 US Senate Election Cycle: https://en.wikipedia.org/wiki/2026_United_States_Senate_elections

 * American Citizens Abroad: https://www.americansabroad.org/

 * US Exit Tax: https://www.irs.gov/individuals/international-taxpayers/expatriation-tax

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Watch or listen to more episodes of The Essential Tax Podcast:

 * https://www.youtube.com/@TheWolfGroupPC

 * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

 * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Episode 15

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Phil Hodgen, Attorney & Principal at Hodgen Law. Phil provides international (cross border) tax planning for multi-national families and service corporations.

Tune in for these key takeaways:

- The complexities of FIRPTA and the U.S. exit tax

- FIRPTA imposes a 15% withholding tax on the sale of U.S. real property by non-residents, with challenges around obtaining timely 8288B waivers

- Effect of the U.S. exit tax on individuals giving up their U.S. citizenship or long-term residency, triggering a mark-to-market tax on worldwide assets

- Strategies for managing FIRPTA and the exit tax

- Phil’s ongoing work with CalCPA on international tax education and compliance

Learn more about Phil Hodgen:

- Visit PHil’s website: https://hodgen.com

- Email: [email protected]

Further resources:

- CalCPA International Tax Lunch Series 2024: https://store.calcpa.org/catalog/activity/international-tax-lunch-series-2024---126312

- FIRPTA - IRC 897: https://www.law.cornell.edu/uscode/text/26/897

- Wolf Group FIRPTA: https://thewolfgroup.com/videos/firpta-tax-withholding-challenges-on-the-sale-of-u-s-real-estate-by-g-4s-other-nonresidents

- US Exit Tax – IRC 877A:  https://www.law.cornell.edu/uscode/text/26/877A

- Wolf Group Exit Tax: https://thewolfgroup.com/videos/us-exit-tax-what-you-need-to-know

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that make your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

 * https://www.youtube.com/@TheWolfGroupPC

 * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

 * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Episode 19

In this episode of The Essential Tax Podcast, Mishkin Santa is joined by Joshua Smeltzer, Tax and Corporate Lawyer at Gray Reed. Gray Reed is a law firm with over 150 attorneys, with a tax controversy and tax litigation practice led by Joshua. They represent clients throughout the U.S., focusing on complex tax issues.

Tune in for these key takeaways:

 * Loper Bright and the Chevron Doctrine – A detailed breakdown of how the Supreme Court's decision in Loper Bright impacts agency deference, especially the IRS, and why it changes the tax litigation landscape.

 * Administrative Procedures Act – How the APA influences tax guidance and how recent challenges, such as in the digital asset space, highlight the IRS's need to follow formal procedures.

 * Private Letter Rulings (PLRs) – A comprehensive look into the purpose, costs, and risks of seeking a PLR, including why they may or may not be the best strategy for a taxpayer.

 * Tax Controversy Strategy – The importance of understanding IRS processes and leveraging litigation hazards in negotiations for favorable outcomes.

 * Future Tax Changes – Insight into the implications of the TCJA sunset and how upcoming tax reforms may need to address the complexities brought to light by cases like Loper Bright.

Learn more about Joshua Smeltzer:

 * Connect with Joshua on LinkedIn: https://www.linkedin.com/in/joshua-smeltzer-bb07714/

 * Follow Gray  Reed on LinkedIn: https://www.linkedin.com/company/grayreed

 * Visit Joshua’s profile on Gray Reed’s Website: https://www.grayreed.com/Our-People/Joshua-D-Smeltzer 

 * Follow Joshua on X: https://x.com/jdsmeltzer

Additional Resources: 

 * Corporate Tax Blog, Dollars & Sense - https://dollarsandsense.grayreed.com

 * Blog post, “Gray Reed Partners Submit Comments on Proposed Treasury Regulations” - https://dollarsandsense.grayreed.com/2024/08/gray-reed-partners-submit-comments-on-proposed-treasury-regulations

 * Loper Bright Supreme Court Case - https://www.supremecourt.gov/opinions/23pdf/22-451_7m58.pdf

 * Chevron Deference - https://www.law.cornell.edu/wex/chevron_deference

 * Skidmore Deference - https://www.law.cornell.edu/supremecourt/text/323/134

 * Administrative Procedures Act - https://www.law.cornell.edu/wex/administrative_procedure_act

 * Stop Corporate Capture Act - https://www.congress.gov/bill/118th-congress/house-bill/1507

 * IRS Private Letter Ruling - https://www.irs.gov/faqs/irs-procedures/code-revenue-procedures-regulations-letter-rulings/code-revenue-procedures-regulations-letter-rulings

 * Maryland Private Letter Ruling - https://marylandtaxes.gov/legal-pubs/tech-bulletins/misc/tb-44.pdf

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that make your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

 * https://www.youtube.com/@TheWolfGroupPC

 * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

 * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Episode 13

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with David Pitts, Actuary and Independent Practitioner. David brings his wealth of experience in actuarial science, focusing on valuation work related to U.S. exit taxes, pensions, and deferred compensation plans. He has a background in mathematics and has worked extensively with retirement plans, class action lawsuits, and more.

David explains his work with organizations like the World Bank and IMF, helping expatriates navigate the complexities of the U.S. exit tax. He also provides insights on actuarial calculations that determine the tax implications for those relinquishing U.S. citizenship or green card status.

Tune in for these key takeaways:

 * Understanding the U.S. exit tax, including the gross present value and net worth tests

 * The actuarial approach to valuing defined benefit plans for expatriates

 * Key tax exclusions for foreign service and after-tax contributions

 * The critical role of actuaries in calculating net present value for exit tax planning

 * Real-world examples of how actuarial science applies to international retirement plans

Learn more about David Pitts:

 * LinkedIn Profile: https://www.linkedin.com/in/davidgpittsfsa

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that make your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

 * https://www.youtube.com/@TheWolfGroupPC

 * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

 * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Episode 13

In this episode of The Essential Tax Podcast, Mishkin Santa talks with Delphine Parigi, a tax lawyer and founder of DPZ Avocats, based in Nice, France. With a master’s degree in International Tax from La Sorbonne and business school HEC, Delphine brings over a decade of experience in advising international groups and high-net-worth individuals on cross-border tax matters. Her boutique firm specializes in assisting clients with French and international tax laws, particularly those facing U.S.-France tax complexities.

Tune in for these key takeaways:

 * The importance of pre-immigration tax planning for U.S. persons moving to France

 * Common cross-border tax issues, such as double taxation on U.S. entities and trusts in France

 * Navigating France's real estate tax regime, including the wealth tax and the use of SCI structures

 * Understanding how the U.S.-France tax treaty now treats French social taxes (CSG, CRDS) as creditable for U.S. taxpayers

 * France’s complex inheritance and gift tax system and planning strategies to reduce tax burdens

Learn more about Delphine Parigi:

 * Connect with Delphine on LinkedIn: https://www.linkedin.com/in/delphine-parigi

 * Follow DPZ Avocats on LinkedIn: https://www.linkedin.com/company/dpz-avocats/posts

 * Website: http://www.dpz-avocats.com 

Resources:

 * Delphine Parigi & DPZ Avocats: http://www.dpz-avocats.com/en/equipe.html

 * Nexia International Network: https://nexia.com

 * US-France FATCA Agreement: https://home.treasury.gov/system/files/131/BilateralAgreementUSFranceImplementFATCA.pdf

 * US-France Income Tax Treaty: https://www.irs.gov/businesses/international-businesses/france-tax-treaty-documents

 * US-France Estate Tax Treaty: https://franceintheus.org/IMG/pdf/french_us_estate_tax_treaty.pdf

 * IRS Practice Unit on French Foreign Tax Credits: https://www.irs.gov/pub/fatca/int_practice_units/ftc_t_010_01_01.pdf

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that make your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

 * https://www.youtube.com/@TheWolfGroupPC

 * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

 * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Episode 11

Watch or listen to this episode of The Essential Tax Podcast when host Mishkin Santa sits down with tax expert Conrad Meyer to unravel the complexities of U.S. and South African cross-border taxation. Conrad is a seasoned tax professional and auditor based in South Africa. Conrad brings a wealth of knowledge from the auditing and accounting practice, Nexia Cape Town, where, as a Partner, he has helped clients navigate the complexities of tax residency, international compliance, and financial migration.

Key Takeaways:

 * Understanding Tax Residency: Conrad discusses the nuances of establishing and ceasing tax residency in South Africa, highlighting the significant tax implications for those moving internationally.

 * Impacts of Recent Tax Law Changes: Recent changes in South African tax law, especially those affecting expatriates and residents with foreign incomes, are explored. Conrad emphasizes the importance of proper exit strategies to avoid dual taxation.

 * Financial Migration and Compliance: The process and importance of financial emigration from South Africa are examined, along with strategies for managing pensions, provident funds, and retirement annuities in compliance with both South African and international tax laws.

 * Practical Tips for Tax Planning: Conrad offers practical advice for those moving to or from South Africa, including the critical steps to take for ensuring tax compliance and optimizing financial transitions.

Learn more about Conrad Meyer:

 * Connect with Conrad on LinkedIn: https://www.linkedin.com/in/conrad-meyer-05888114 

 * Visit Nexia Cape Town’s Website: http://www.nexiacapetown.com 

 * Email: [email protected]

Resources:

 * SARS link to foreign income and exemptions: https://www.sars.gov.za/individuals/tax-during-all-life-stages-and-events/foreign-employment-income-exemption

 * Nexia Cape Town Budget Booklet: https://www.nexiacapetown.com/insights/nexia-publications

 * South Africa Know Your Client Rules: https://www.kychub.com/blog/kyc-requirements-south-africa/#:~:text=This%20act%20plays%20a%20pivotal,of%20address%20(utility%20 bills)

 * South African Revenue Service: https://www.sars.gov.za

South Africa OECD Grey list:

*https://www.reuters.com/business/finance/south-africa-should-get-off-global-regulators-grey-list-2025-says-central-bank-2024-03-13

*https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that make your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

 * https://www.youtube.com/@TheWolfGroupPC

 * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

 * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Episode 10

In this episode of The Essential Tax Podcast, Mishkin Santa dives deep into the intricacies of the Foreign Account Tax Compliance Act (FATCA), exploring its impact and requirements. This masterclass session is crucial for anyone dealing with international tax obligations, particularly those with financial interests overseas.

Tune in for these key takeaways:

 * Understanding the significance and implications of FATCA for individuals and foreign financial institutions.

 * Detailed explanation of essential FATCA forms such as Form 8966 and Form 8938, including who needs to file them and the consequences of non-compliance.

 * Practical advice on avoiding common pitfalls in FATCA compliance and how to respond to IRS notices regarding foreign accounts.

 * Insights into the international scope of FATCA, including how it affects U.S. taxpayers living abroad and the specific requirements they face.

 * Strategies for effective management and reporting of foreign financial assets to ensure compliance and avoid hefty penalties.

Resources:

 * FATCA: https://www.govinfo.gov/content/pkg/PLAW-111publ147/pdf/PLAW-111publ147.pdf#page=27

 * IRS Form 8938: https://www.irs.gov/pub/irs-pdf/f8938.pdf

 * Instructions to Form 8938: https://www.irs.gov/pub/irs-pdf/i8938.pdf

 * Form 8966: https://www.irs.gov/pub/irs-pdf/f8966.pdf

 * Instructions to Form 8966: https://www.irs.gov/pub/irs-pdf/i8966.pdf

 * Treasury Regulation 1.1471-4: https://www.law.cornell.edu/cfr/text/26/1.1471-4

 * Treasury Regulation 1.1471-5: https://www.law.cornell.edu/cfr/text/26/1.1471-5

 * GAO Report from April 2019 on Foreign Asset Reporting: https://www.gao.gov/assets/700/698581.pdf

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that make your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas.

Watch or listen to more episodes of The Essential Tax Podcast:

 * https://www.youtube.com/@TheWolfGroupPC

 * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

 * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Episode 09

In this episode of The Essential Tax Podcast, Mishkin Santa covers various important tax developments for August 2024. This episode dives into recent changes in international tax laws across several countries, including Canada, the Cayman Islands, Italy, and New Zealand. Mishkin also discusses the latest IRS updates on digital assets and the implementation of new tax forms related to cryptocurrencies. The podcast provides an in-depth analysis of current FBAR litigation cases and updates on FinCEN's new reporting requirements, offering valuable insights for both tax professionals and individuals navigating complex tax scenarios.

Tune in for these key takeaways:

 * Updates on International Tax Law: Learn about the significant tax changes in Canada, Cayman Islands, Italy, and New Zealand, and how they might impact global taxpayers.

 * Digital Assets and IRS Guidelines: Get the latest on IRS regulations for cryptocurrencies, including the new form 1099 DA for digital asset transactions.

 * FBAR Litigation and Penalties: Understand the recent developments in FBAR litigation and what it means for individuals with foreign financial assets.

 * FinCEN Reporting Requirements: Discover the new FinCEN BOI requirements and their implications for U.S. businesses.

 * Efficient Tax Practices: Gain insights into handling complex tax issues effectively, with examples from current legal cases and IRS updates.

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Watch or listen to more episodes of The Essential Tax Podcast:

 * https://www.youtube.com/@TheWolfGroupPC

 * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

 * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa

In an increasingly interconnected world, Athletes, Entertainers and Influencers often generate income across borders, presenting unique tax challenges. This webinar is tailored for the professionals advising clients with international earnings.

Topics include:

* Key differences in income, withholding, and other related tax obligations across the USA, Europe and India

* Understanding residency, application of income tax treaties, and cross-border taxation rules for globally mobile clients

* Strategies for managing global tax efficiency liabilities, and compliance issues including international informational reporting, and mitigation of penalty traps

* IRS FAQ on Swag Bags: https://www.irs.gov/pub/irs-news/ir-06-128.pdf

* Derrick Henry $250,000 Diet: https://www.essentiallysports.com/nfl-active-news-after-two-fifty-thousand-diet-went-viral-ravens-derrick-henry-reveals-painful-truth-about-his-eating-habits/

* Nano-Influencers Article: https://hbr.org/2024/09/when-it-comes-to-influencers-smaller-can-be-better

* US Tax Treaty Table 1 - Tax Rates on Income other Personal Services: https://www.irs.gov/pub/irs-lbi/tax-treaty-table-1.pdf

* US Tax Treaty Table 2 – Compensation for Personal Services: https://www.irs.gov/pub/irs-lbi/tax-treaty-table-2.pdf

* US Tax Treaty Table 3 – List of US Tax Treaties: https://www.irs.gov/pub/irs-lbi/tax-treaty-table-3.pdf

* US Tax Treaty Table 4 – Limitation on Benefits: https://www.irs.gov/pub/irs-lbi/Tax_Treaty_Table_4.pdf

* US Totalization or Social Security Agreements: https://www.irs.gov/individuals/international-taxpayers/totalization-agreements

* IRS Audit Technique Guide for Hobby Losses: https://www.irs.gov/pub/irs-pdf/p5558.pdf

* The Money Game: https://www.amazon.com/The-Money-Game-Season-1/dp/B0D7KT8VQM

* Name, Image, Likeness (NIL) Taxation: https://www.taxpayeradvocate.irs.gov/get-help/general/nil/

* Name, Image, Likeness (NIL) Agreements: https://www.taxpayeradvocate.irs.gov/news/nta-blog/nta-blog-student-athletes-involved-in-nil-agreements-should-be-aware-of-their-tax-obligations/2023/12/

* Wolf Group Blog Post on Taxation of Cross-Fit Athletes: https://thewolfgroup.com/blog/the-2018-crossfit-games-offer-more-than-a-taxing-workout-they-illustrate-how-new-u-s-tax-law-%C2%A7199a-affects-non-resident-aliens/

The Essential Tax Podcast with Mishkin Santa, Episode 08

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with David Tzimenakis, one of the managing directors at The US Tax Team New Zealand. David brings his expertise in U.S. tax issues for expatriates and covers a wide range of topics from transitional residency rules in New Zealand to the complex world of tax implications for foreign investments. The US Tax Team is a New Zealand-based, US tax practice. They assist US citizens, green card holders, and others with a link to the US, with their US tax obligations. This includes tax consultancy and tax return preparation.

Tune in for these key takeaways:

 * Insight into the New Zealand and U.S. tax systems, focusing on the unique challenges faced by U.S. expatriates in New Zealand

 * Detailed discussion on specific tax rules like the FIF (Foreign Investment Fund) rules and the PIE (Portfolio Investment Entity) tax rules in New Zealand

 * Advice on pre-migration tax planning, the importance of understanding transitional residency, and the potential tax traps for new residents

 * Exploration of international tax comparison, particularly the treatment of imputation credits in New Zealand and their contrast with the U.S. tax system

Learn more about  David Tzimenakis:

 * LinkedIn Profile: https://www.linkedin.com/in/david-tzimenakis-668706119/ 

 * Visit The US Tax Team’s website: https://www.usatax.nz

Further Resources: 

 * The US Tax Team – KiwiSaver explainer - https://www.usatax.nz/knowledge-centre/kiwisaver-trust-reporting-on-form-3520-and-3520a

 * The US Tax Team – Tips for moving to NZ - https://www.usatax.nz/knowledge-centre/5-top-tax-tips-for-us-citizens-moving-to-new-zealand

 * PFIC – A brokerage example - https://www.usatax.nz/knowledge-centre/form-8621-pfics-sharesies-us-tax-trap

 * The US Tax Team – Contact Us - https://www.usatax.nz/contact-8

 * Understanding FIF Taxation - https://www.johnstonlaw.nz/post/navigating-the-challenges-understanding-the-application-of-the-fif-rules-in-new-zealand

 * Transitional residency in NZ - https://www.johnstonlaw.nz/post/get-your-tax-residency-right

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About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax, guiding you through a range of tax topics in a way that cuts through the jargon, acronyms, and complexities that make your eyes glaze over, so that you can understand the latest developments and how they relate to you.

Watch or listen to more episodes of The Essential Tax Podcast:

 * https://www.youtube.com/@TheWolfGroupPC

 * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944

 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf

Connect and learn more from your host, Mishkin Santa:

 * Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The Wolf Group, P.C. on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on Wolf Group, P.C.’s website: https://thewolfgroup.com/our-people/mishkin-santa