Fabien Lehagre’s Post

Unfortunately, this is too little too late to help me. I paid the $2,350 when I expatriated. Fat chance any refunds will be offered! But this will be a big help to many people considering expatriation but who are unable to afford it. I know that many people who want to expatriate don't because they can't afford the fee. Once the fee drops, I imagine we will see a jump in expatriations. If you are considering expatriating, please get pre-expatriation tax advice so you understand the tax consequences and don't accidentally get classified as a covered expatriate when you could have been a non-covered expatriate. Covered expatriates are subject to an exit and tax and any gifts or inheritances received by US persons by a covered expatriate are subject to US gift or estate at the highest rate then in effect (currently 40%). This can be devastating to US recipients of gifts or inheritances. Also make sure that you hire a competent tax professional to prepare your final tax return and Form 8854. For more information about expatriating, check out my video "The Ultimate Guide to Expatriating from the U.S." here: https://buff.ly/3F2IGEv You can also use my Expatriation Exit Tax Calculator to determine if you are a covered expatriate or not and estimate your exit tax. You can download it here: https://buff.ly/3IFCcyu #tax #taxation #internationaltax #taxpolicy #taxtherich #transparency #wealth #wealthplanning #wealthy #success #investing #familyoffice #assetprotection #wealthprotection #freedom #security #expatriation #usinvestment #usrealestate #taxplanning #expatriation

🤔 1. Common industry issues and where Re:Test can help... Misunderstanding Testing - Companies do not always understand the differing test phases, terminology and best practice a 'Quality Assurance' analyst can deliver. However at Re:Test we want to Re:Engage with our partners to take them on the test journey. We live and breath software testing so let us support you IT project delivery. A Re:Test QA will understand your projects business requirements, have technical experience across all testing disciplines and can deliver best practice standards from Discovery, Planning, Execution and Closure phases of any software delivery project. Come and see how Re:Test can engage your company with it's software delivery lifecycle 📧 info@retestgroup.com ☎ 07525173428 #testlife #retestgroup

[ Offshore Tax ] Are Insurance Payouts in Singapore Taxable to US Expats? Most earned and passive investment income is taxable in the US. However, there are certain types of receipts that are excluded from taxable income. These include life insurance proceeds received by the qualified beneficiary, tax-exempt interest, and property acquired by bequest, devise, or inheritance. If a contract, which is a life insurance contract under applicable law, does not meet the definition of a life insurance contract under section 7702, the excess of the amount paid due to the death of the insured over the net surrender value of the contract shall be deemed to be paid under a life insurance contract for purposes of section 101.7. In other words, the normal rules for life insurance proceeds will apply. On the other hand, if the policy is not a life insurance policy under applicable law, or if the entity issuing the policy is otherwise treated as a “passive foreign investment company” (PFIC) under U.S. tax law, the proceeds on death may be taxed as if it were a PFIC. The ownership of a PFIC by a U.S. individual may result in adverse current annual U.S. income tax consequences, as well as adverse U.S. income tax consequences upon the death of the owner. For example, any actual or deemed disposition of a PFIC during lifetime, possibly including relinquishing U.S. citizenship or U.S. residency, gifting the policy, or even pledging the policy for a loan, may result in adverse U.S. income taxation under the excess distribution regime. Further, the death of the policy owner may also trigger a deemed disposition and result in adverse U.S. income taxation under the excess distribution regime. The owner’s interest in the foreign insurance company will not be treated as a PFIC if: 1. The entity is a “qualifying insurance corporation”, and 2. It derives its income in the active conduct of an insurance business. #USA #Singapore #insurance #internationaltax #taxplanning #internationalbusiness #offshore

🤔 Day 2. Common industry issues and where Re:Test can help... 💷Cost of Testing💷 - Companies can have the understanding that the cost to test software solutions is expensive and not a necessary expense. This thinking can lead to more costs with extensions of project time lines, it can deliver sub-standard code into production. Raising the cost to change and fix late, with the risk of production downtime. ✔ However at Re:Test, we can create a test strategy which will match your companies budget and timelines. Re:Test offer flexible levels of testing by hour or day, depending on your delivery plan, to align with your budgetary needs. Our goal is to provide you with a comprehensive solution that maximises value without compromising quality. Get in touch today to see how Re:Test can create a plan for your companies budget needs. 📧 info@retestgroup.com ☎ 07525173428 #testlife #retestgroup

On that so-called “valley of death”, problem-framing and incentives Reporting from a thought-provoking panel co-organized by the #QBI at UCSF and #a16z – Thank you! A redeeming feature of the SF Bay area is that it helps gather various heavy-hitters for a live event, but still, you have to make it happen. The ostensible topic was the bridging of what these academic / entrepreneurs touchingly call “the Valley of Death” between academic research and VC-funded company formation (never mind that this “valley” stretches all the way to drug *sales* - quite a bit farther than that). What struck me was the lack of clarity about the nature of the problem. One couldn’t pin the panelists down (I tried) on whether the problem was with the “division of the spoils” (a zero-sum game between founders and VCs) or with the flow of innovation from academic labs to company formation. Certainly, the first one was an impolite question in a mixed company of academics and VCs (kudos to Ron Leuty for pushing a bit harder on this). The second one, using a “growing-the-pie” metaphor, can bring smiles all around, until one realizes that it invokes universities playing Venture Investor to “create more value” – for the greater good, of course (the word “socialism” was actually used twice). Good luck with that one! Now, to the more impolite point. It is implicit (and occasionally explicit) in that setting that “more academic research” will yield “more therapeutics” eventually (we don’t fund the NIH to improve the lives of fruit flies and zebrafish – I hope). But are we so sure? A recent publication documented (Arash Sadri, https://lnkd.in/gxTDCm6X) and most industry denizens suspected that most approved drugs were not, in fact, born of target-based discovery. However, to the extent that academic scientists spend their time “deciphering biology”, their output leads usually to this very “target-based discovery”. So, is the whole biolab-to-pharmacy project misguided? This would be an overstatement! But it begs the question of whether spinning off more (doomed) VC-backed companies would yield more therapeutics. It is now amply documented (and increasingly known) that the biopharma industry is really bad at developing new drugs (and is getting worse, see e.g. Scannell, doi:10.1038/nrd3681). I’m not sure that opening the academic funnel wider at the top will yield more drugs at the bottom. But of course, VCs wouldn’t care – they’re long gone, by then.

Posh is the typical European VC trying to relate to the entrepreneurs. David Beckham is the entrepreneurs who know better. TGIF! #vc #venturecapital #startups #entrepreneurs #entrepreneurship #funding #tech #technology #innovation #money #business

The opinion in Christensen v. United States (U.S. Court of Federal Claims 1:20-cv-00935) was due to be released to the public soon but it appears the parties are in settlement discussions. So we will not have an opinion from the Court in this case as to whether a taxpayer can claim a foreign tax credit against Net Investment Income Tax (NIIT). Interestingly, the government is going to give the taxpayers their full refund of tax paid as NIIT without admitting it is doing so as a foreign tax credit against NIIT. (French Tax Treaty in this case). However, there is another case in the U.S. Court of Federal Claims filed in May 2023 involving the same lawyers on both sides. This case involves the U.S. / Canada Income Tax Treaty and the dollar amount is much higher. Same issue - can a foreign tax credit offset NIIT under the treaty? Bruyea v. United States (U.S. Court of Federal Claims 1:23-cv-00766). The government filed its Answer in the case today. Attached.

Do you know about the Carbon Border Adjustment Mechanism (CBAM)? If not, you should start paying attention. The EU just released reporting rules that come into force this month and will affect hundred of products sold into the EU. CBAM will require many industries to start--or significantly increase--their decarbonization strategies. Check out this link to start learning more. https://lnkd.in/gMYmUtAn

Nassau County 2023/24 School Tax Bills deliver an October scare to homeowners!   As Nassau County residents receive their 2023/24 school tax bills they may notice a reduced tax rate. This is good news, right?! Not necessarily, as it does not automatically mean a reduced tax bill. As Nassau County residents may remember, the County instituted a reassessment on all real property for the tax year 2020/21. To help residential property owners cope with large assessment increases from 2019/20 to 2020/21, the County offered up the “Taxpayer Protection Plan (TPP)” as part of the reassessment. The TPP exemption was intended to soften the blow of these increases by phasing in real property tax increases over a 5-year period, rather than burdening the owner with one large increased tax bill. Unfortunately, the TPP is also the perfect example of political leaders opting to kick the can down the road.   The 2023/24 tax year marks the fourth year of the TPP’s 5-year phase-in period so homeowners with large TPP exemptions are seeing tax bills soar despite decreased tax rates in a majority of school districts. As some homeowners have discovered, the only possible defense to these tax increases are annual challenges to reduce your assessment. While not everybody may have a case for a reduction, this certainly an excellent reason for homeowners to seek guidance by an attorney experienced in property tax assessment appeals. Thank you to Nancy DeBiasi Gillen for this week's Tax Tracker! #nassaucounty #taxlaw #realpropertytax

The future DM FER X: key points and issues about the new massive CfD tool for Italian renewables. The translation of the entire article we wrote yesterday for Quotidiano Energia (thanks Romina Maurizi). https://lnkd.in/drugcAs5