The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 14

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Mag. Christina Pichler, owner, auditor & tax advisor at Fidesta Consulting and Taxes, located in Wein, Austria. Christina is an attorney and has worked as a professor of corporate law at The Vienna University of Economics and Business. Christina has been established in the Austrian tax industry for over 25 years.

Tune in for these key takeaways:

• An outline of how a person could become a tax resident in Austria.

• A discussion of some unique characteristics of the Austrian tax system and how they could affect a taxpayer or business that has Austrian reporting obligations.

• Some common issues that Americans looking to move to Austria might experience and how to prepare for them in advance.

• Discussion of the mechanics behind Austrian pension and trust systems.

• A brief overview of several Austrian tax structures that are unique to self-employed individuals.

• An outline of Austrian Usufructs and Wohngebrauchsrechts and how they can benefit a taxpayer that is undertaking Austrian estate planning.

• Insight into some American informational reporting requirements that relate to Austrian assets, domicile, income, and estate planning.

Learn more about Christina Pichler:

• Leave a message with a question on Fidesta’s website: https://www.fidesta.at/de/kanzlei/kontakt/

• Email Fidesta directly: office@fidesta.at

• View Christina Pichler’s profile on Fidesta’s website: https://www.fidesta.at/de/kanzlei/ansprechpartner/

Further Resources:

• US-Austria Totalization Agreement: https://www.ssa.gov/international/Agreement_Pamphlets/austria.html

• US-Austria Income Tax Treaty: https://www.irs.gov/businesses/international-businesses/austria-tax-treaty-documents

• US-Austria Gift and Estate Tax Treaty: https://www.jct.gov/getattachment/95a06bdf-a90e-4d83-94cc-6a6fd5c9e5da/s-34-82-2497.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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 13

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Catarina Breia, Partner & Head of Tax at Nexia – Santos Carvalho & Associados, SROC, S.A. Catarina leads the tax consulting division at Nexia – Santos Carvalho & Associados, located in Portugal. She has been a tax arbitrator in the Portuguese Administrative Arbitrage Court, is a member of the Portuguese Tax Association and International Fiscal Association, and holds a Master Executive in Taxation and Tax Planning from Catholic University of Portugal.

Tune in for these key takeaways:

• Insight into the attractive location, climate, lifestyle, job market, and cost of living in Portugal that draws so many US expats and international celebrities to the beautiful country.

• The importance of strategizing before undertaking an international relocation to mitigate any tax burden and maximize the tax benefits of living in Portugal.

• A discussion of Portuguese criteria for personal tax residency and commonly associated risks of not researching these before relocating to Portugal.

• An outline of frequently utilized visas and Portuguese golden visa options, including a description about relevant tax regimes (NHR, IFICI)

• Information about inheritance and gift taxation in Portugal and how their policy of no wealth taxation can provide unique tax benefits in this area.

• Discussion surrounding the unique opportunities available in Portugal to entrepreneurs and business investors.

Learn more about Catarina Breia:

• View Catarina Breia’s profile on Nexia – Santos Carvalho & Associados’ website: https://santoscarvsroc.pt/en/a-equipa/catarina-breia/

• Connect with Catarina Breia on LinkedIn: https://www.linkedin.com/in/catarina-breia-04159b3/

• Follow NEXIA – Santos Carvalho & Associados on LinkedIn: https://www.linkedin.com/company/nexia-sca/posts/?feedView=all

• Visit The Nexia YouTube Channel: https://www.youtube.com/channel/UCbY1iQu_U1vzIhAPCEtQJGQ/videos

• Follow Nexia – Santos Carvalho & Associados on Facebook: https://www.facebook.com/NEXIASANTOSCARVALHO/

Further Resources:

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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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 12

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Jason Levy, JD, Counsel at Grossman, Young & Hammond. Jason has been practicing law in the United States for over 28 years. Previously, Jason served as Senior Attorney with the Office of the General Counsel, Immigration Law Division at the U.S. Department of Homeland Security (DHS). While at DHS, Jason advised policy, operational, and legal leadership on a wide array of immigration-related rulemakings and policies instituted by DHS and its component agencies (USCIS, CBP, and ICE), with a primary focus on employment-based immigration policies.

Tune in for these key takeaways:

• A brief history of the development of immigration law in the US

• Ways to obtain permanent residency with the US

• When the US government might change or update the current US Immigration statutes, and when they won’t

• In-depth discussion of different types of US Visas, how to obtain each one, and speculation of how the criteria may change in the future

• Discussion about the status of the US government’s Gold Card and Platinum Card initiatives and how they might affect US immigration law and tax residency

• Common misconceptions and certain facts about how a person might inadvertently surrender their US Green Card and options for those individuals to maintain or preemptively protect their LPR status

Learn more about Jason Levy:

• Visit the Resources page on Grossman Young & Hammond’s website: https://www.grossmanyoung.com/resources/

• View Jason Levy’s profile on Grossman Young & Hammond’s website: https://www.grossmanyoung.com/attorneys/jason-levy/

• Connect with Jason Levy on LinkedIn: https://www.linkedin.com/in/jason-levy-5776a41/

• Follow Grossman, Young & Hammond on LinkedIn: https://www.linkedin.com/company/grossmanyoung/

• Visit Grossman, Young & Hammond’s YouTube Channel: https://www.youtube.com/@grossmanyounghammondllc73

• Follow Grossman, Young & Hammond on Facebook: https://www.facebook.com/grossmanyoung/

Further Resources:

• US DOJ Executive Office of Immigration Review - https://www.justice.gov/eoir

• US DOJ Matter of Lok (1981) - https://www.justice.gov/sites/default/files/eoir/legacy/2012/08/14/2878.pdf

• Matter of Wong (1977) - https://www.justice.gov/sites/default/files/eoir/legacy/2012/08/17/2549.pdf

• Gold Card Website - https://trumpcard.gov/

• Matter of Kane (1975) - https://www.justice.gov/sites/default/files/eoir/legacy/2012/08/17/2371.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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 11

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Nghi Huynh, Transfer Pricing Partner-in-Charge, Armanino Advisory LLC. Nghi is a proven tax professional with over 20 years of experience in transfer pricing, research, audit, and tax planning projects within Big 4 public accounting firms.

Tune in for these key takeaways:

• An overview of Transfer Pricing models, planning, and industries that commonly utilize this method

• What Transfer Pricing might look like for a small startup company entering into international markets that include mid-size to large competitors

• When and how to enlist assistance with transfer pricing beyond tangible goods (services, IP, cost-sharing, financing arrangements)

• Situations that might call for Advance Pricing Agreements or Mutual Agreement Procedures

• An overview of typical Transfer Pricing documentation, when to refresh, and how best to maintain long-term

• Details about common intercompany funding pitfalls when multinational enterprises establish and expand their foreign operations

• A discussion of a few of the most efficient ways for parent companies to fund foreign subsidiaries (loans, capitalization, short-term AR/AP)

• Updates on the current state of transfer pricing litigation with the IRS and high-risk jurisdictions for audits and adjustments

Learn more about Nghi Huynh:

• Visit the Transfer Pricing page on Armanino’s website: https://lnkd.in/gZHF5hjY

• View Armanino’s website: https://www.armanino.com/

• Connect with Nghi Huynh on LinkedIn: linkedin.com/in/nghi-huynh

• Check out Armanino’s most recent Transfer Pricing newsletter: https://www.linkedin.com/posts/tax-armanino_armanino-tariff-advisory-ugcPost-7371204268365737984-xq5Z/?utm_source=social_share_send&utm_medium=member_desktop_web&rcm=ACoAAADbAhkB5xgWo_NM0eh5PpgcFdl7gNb6C_A

• Follow Armanino on LinkedIn: https://www.linkedin.com/company/armanino/

• Visit Armanino’s YouTube Channel: https://www.youtube.com/c/armanino

• Follow Armanino on Facebook: https://www.facebook.com/Armanino.HQ/

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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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 10

In this episode of The Essential Tax Podcast, your host, Mishkin Santa, dives into some hot tax topics for #InternationalPodcastDay.

Tune in for these key takeaways:

• Social media & Influencer guidance for tax practitioners and relevant case law.

• When a tax practitioner might be considered culpable for advice offered on social media.

• Some of the dangers of a one-size-fits-all approach to professional tax advice.

• The importance of a disclaimer and when offering tax advice on social media.

• An outline of the One Big Beautiful Bill Act’s changes to IRS rules for charitable contributions and why this might be important for your own personal tax planning.

• A brief guided tour of the brand-new IRS Schedule 1A that pertains to certain tax deductions.

• An upcoming change at the IRS, stemming from an Executive Order by the US President, that will change the way refunds & paper checks are accepted and/or processed.

Further Resources:

• 2025 “Draft” Schedule 1-A: https://www.irs.gov/pub/irs-dft/f1040s1a--dft.pdf

• Executive Order – Modernizing Payments to and from America’s Bank Account: https://www.whitehouse.gov/presidential-actions/2025/03/modernizing-payments-to-and-from-americas-bank-account/

• TWG Blog Post - https://thewolfgroup.com/blog/the-irs-will-stop-issuing-refunds-via-paper-check-in-september-2025/

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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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

Tune in to this mini episode of The Essential Tax Podcast for practical tips and updates on a timely topic in the international tax realm. Your host, Mishkin Santa, will briefly guide you through the most up-to-date information on this hot tax topic as well as provide his invaluable analysis and expert recommendations.

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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 9

In this episode of The Essential Tax Podcast, Mishkin Santa discusses recent news items related to FinCEN Form 114 (FBAR) requirements, and how they will affect US and international tax reporting.

Tune in for these key takeaways:

• A brief history of the FBAR’s origins in the Bank Secrecy Act of 1970.

• A summary of which taxpayers need file an FBAR and an explanation of the aggregate reporting threshold that triggers the requirement.

• Tips for recordkeeping and due diligence that can aid in making ongoing FBAR reporting and potential audit defense more manageable.

• A discussion of recent court cases that have affected judicial treatment of FBAR disputes and penalty assessments.

• An overview of current penalties for noncompliance with FBAR filing requirements.

Further Resources:

• Bank Secrecy Act of 1970 - https://www.fincen.gov/resources/statutes-and-regulations/bank-secrecy-act

• IRS FBAR Practice Unit - https://www.irs.gov/pub/fatca/int_practice_units/fincen-form114-fbar.pdf

• IRS Schedule B - https://www.irs.gov/forms-pubs/about-schedule-b-form-1040

• United States v. Timberly E. Hughes - https://law.justia.com/cases/federal/appellate-courts/ca9/23-15712/23-15712-2024-08-21.html

• IRM 4.26.16.4.4.1 - https://www.irs.gov/irm/part4/irm_04-026-016

• United States v. Saydam - https://dockets.justia.com/docket/california/candce/4:2022cv07371/404157

• United States v. Rohrbasser - https://dockets.justia.com/docket/connecticut/ctdce/3:2024cv00959/159875

• United States v. Rotta - https://www.justice.gov/opa/pr/wealthy-miami-man-pleads-guilty-decades-long-scheme-defraud-irs

• United States v. Leeds - https://law.justia.com/cases/federal/district-courts/idaho/iddce/1:2022cv00379/50692/36/

• United States v. Gernot John Noell - https://www.courtlistener.com/docket/65386409/united-states-v-noell/

• United States v. Stephen M. Kerr - https://www.courtlistener.com/docket/16355120/united-states-v-kerr/

• United States v. Sagoo - https://dockets.justia.com/docket/texas/txndce/4:2024cv01159/397369

• Kurotaki v. United States - https://law.justia.com/cases/federal/district-courts/hawaii/hidce/1:2022cv00063/157629/50/

• Bittner v. United States - https://www.supremecourt.gov/opinions/22pdf/21-1195_h3ci.pdf

• IRS Memo SBSE-04-0723-0034 - https://www.irs.gov/pub/foia/ig/sbse/sbse-04-0723-0034-redacted.pdf

• 2025 FBAR Penalty Adjustment Table - https://www.federalregister.gov/documents/2025/01/17/2025-01374/financial-crimes-enforcement-network-inflation-adjustment-of-civil-monetary-penalties

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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 makes 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:

* YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

Title: Substantiation for Conversion of Personal Residence to Rental Property

Show Notes:

• Smith v. Commissioner, T.C. Memo 2025-24 (March 24, 2025)

• Treasury Regulation 1.167(g)-1: https://www.law.cornell.edu/cfr/text/26/1.46-3

About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, MishkinSanta takes on the complex world of tax — all the jargon, acronyms, and stuffthat makes your eyes glaze over, and explains it in an impactful way tounderstand the complex and unknown areas.

Watch or listen to more episodes of The Essential TaxPodcast:

 * YouTube: 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 withMishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The WolfGroup on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on The Wolf Group’swebsite: https://thewolfgroup.com/our-people/mishkin-santa

Title: Placed in Service Rules Update

Show Notes:

• Lentine v. Commissioner, T.C. Docket No. 12443-21 (March 25, 2025)

• Treasury Regulation 1.167(a)-10: https://www.law.cornell.edu/cfr/text/26/1.167(a)-10

• Treasury Regulation 1.46-3: https://www.law.cornell.edu/cfr/text/26/1.46-3

About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, MishkinSanta takes on the complex world of tax — all the jargon, acronyms, and stuffthat makes your eyes glaze over, and explains it in an impactful way tounderstand the complex and unknown areas.

Watch or listen to more episodes of The Essential TaxPodcast:

 * YouTube: 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 withMishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The WolfGroup on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on The Wolf Group’swebsite: https://thewolfgroup.com/our-people/mishkin-santa

Title: Foreign Rental Property and Qualified Business Reporting

Show notes:                                       IRS: Form 8858: https://www.irs.gov/pub/irs-pdf/f8858.pdf                         IRC 168: https://www.law.cornell.edu/uscode/text/26/168                             Treasury Regulation 1.989(a)-1: https://www.law.cornell.edu/cfr/text/26/1.989(a)-1About The Essential Tax Podcast:

In each episode of The Essential Tax Podcast, MishkinSanta takes on the complex world of tax — all the jargon, acronyms, and stuffthat makes your eyes glaze over, and explains it in an impactful way tounderstand the complex and unknown areas.

Watch or listen to more episodes of The Essential TaxPodcast:

 * YouTube: 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 withMishkin on LinkedIn: https://www.linkedin.com/in/msanta

 * Follow The WolfGroup on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

 * Read Mishkin’s bio on The Wolf Group’swebsite: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 8

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Austin C. Carlson, JD, CPA, Partner at Gray Reed. As a business lawyer and CPA, Austin brings a unique and rare set of skills and perspectives to every area of his practice, which includes corporate and tax counsel on M&A deals, complex corporate and tax planning for domestic and international transactions, foreign account and income disclosure and penalty abatement issues. Give this episode a listen to learn more about non-willful statements and their importance to the IRS’s Streamlined Filing Compliance Procedures.

Tune in for these key takeaways:

• A brief history of the IRS Offshore Voluntary Disclosure Program (OVDP), Streamlined Filing Compliance Procedures (SFCP), and Amnesty Programs in general

• The role of accountant vs. an attorney in amnesty program disclosures with a specific discussion related to the preparation of the Non-Willful Statement

• The timeline of involvement for an attorney in an amnesty program disclosure

• The key differences of Willful vs. Non-Willful behavior including the associated civil penalties

• A comprehensive discussion of the best practices and contents required for the Non-Willful Statement required for a Streamlined Filing Compliance Procedures (SFCP)

• A discussion related to the IRS processing time, expected responses, follow ups post Streamlined Filing Compliance Procedures (SFCP) submission

Learn more about Austin C. Carlson:

• Visit the News & Resources page on Gray Reed’s website: https://www.grayreed.com/NewsResources
• View Austin C. Carlson’s profile on Gray Reed’s website: https://www.grayreed.com/Our-People/Austin-C-Carlson

• Connect with Austin C. Carlson on LinkedIn: https://www.linkedin.com/in/austin-carlson-jd-cpa-63031029/

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

• Visit Gray Reed’s YouTube Channel: https://www.youtube.com/@GrayReedLaw

• Follow Gray Reed on Facebook: https://www.facebook.com/GrayReedLaw/

Further Resources:

• SDOP FAQ 13: https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures-for-us-taxpayers-residing-in-the-united-states-frequently-asked-questions-and-answers

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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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 8

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Nick Hart, VAT Partner, Saffery – United Kingdom; Michael Salman, Director, Nexia DHW – Netherlands; and Tobias Barkschat – Senior Manager, Nexia GmbH – Germany. Nick, Michael, and Tobias have a wealth of combined experience in navigating the European VAT. Join us for this episode to learn more about how this tax could apply to your business or you personally.

Tune in for these key takeaways:

• Critical information about the purpose, process to register, and collection procedures for the European Value Added Tax (VAT)

• How to obtain and utilize an Article 23 license in the Netherlands to assist in minimizing VAT burden

• Inventory and physical presence requirements in the UK, Germany, and the Netherlands, and recommendations for best practices to navigate them as a US business owner
• Similarities between permanent (fixed) establishment versus local entity establishment in the Netherlands and Germany, and how this choice can affect the VAT

• A comparison of the UK VAT burden in business-to-business and business-to-consumer setups, and how this supply chain variation can shift the tax liability between business and consumer

• The European Union’s ‘one-stop shop’ proposition and how it could simplify VAT among different European countries

• A discussion of VAT invoices, deadline requirements, reporting thresholds, and other variances between the UK, Germany, and the Netherlands

• An overview of the rapid evolution of VAT and how it can affect businesses entering the European marketplace

• Tips for corrective VAT compliance, amnesty programs, and a discussion of potential penalties

• Information about VAT pitfalls to eCommerce entry into the European market, and how to avoid them

• A brief overview of the Nexia network structure and the many advantages the cooperation amongst its practitioners offers to international taxpayers and businesses

Learn more about today’s guests:

• Connect with Nick Hart on LinkedIn: https://www.linkedin.com/in/nick-hart51/?originalSubdomain=uk

• View Nick Hart’s profile on Saffery’s website: https://www.saffery.com/our-people/nick-hart/

• Visit Saffery’s YouTube Channel: https://www.youtube.com/channel/UCXR88yBPil9YZLO_5A__lzQ

Connect with Michael Salman on LinkedIn: https://www.linkedin.com/in/michaelsalman/

• Visit De Hooge Waerder’s YouTube Channel: https://www.youtube.com/user/dehoogewaerder

• Follow De Hooge Waerder on Facebook: https://www.facebook.com/dehoogewaerder/photos/?locale=nl_NL&_rdr

• Connect with Tobias Barkschat on LinkedIn: https://www.linkedin.com/in/tobias-barkschat-2a0b53142/?originalSubdomain=de

• View Tobias Barkschat’s profile on Nexia GmbH’s website: https://www.nexia.de/en/our-people/detail/tobias-barkschat

• Visit Nexia’s YouTube Channel: https://www.youtube.com/channel/UCbY1iQu_U1vzIhAPCEtQJGQ

Further Resources:

• VAT eCommerce - One Stop Shop: https://vat-one-stop-shop.ec.europa.eu/news-reports/report-application-vat-e-commerce-package-2024_en

• EU Taxation & Customs Union VAT Landing Page: https://taxation-customs.ec.europa.eu/taxation/vat_en

• VAT Rules & Rates: https://europa.eu/youreurope/business/taxation/vat/vat-rules-rates/index_en.htm

• Nexia Slides on European Indirect Tax Services for US Outbounds: https://thewolfgroup.com/wp-content/uploads/2025/07/Nexia-European-VAT-for-US-outbounds-July-2025.pptx

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

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 6 

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Austin C. Carlson, JD, CPA, Partner at Gray Reed. As a business lawyer and CPA, Austin brings a unique and rare set of skills and perspectives to every area of his practice, which includes corporate and tax counsel on M&A deals, complex corporate and tax planning for domestic and international transactions, foreign account and income disclosure and penalty abatement issues including the Streamlined Filing Compliance Procedures and Delinquent International Information Return Submission Procedures. Tune in to hear Austin and Mishkin discuss key provisions of the One Big Beautiful Bill Act (OB3) that was recently signed into law by President Trump. 

Tune in for these key takeaways: 

• A comprehensive review of the Qualified Opportunity Zone (QOZ) Rules introduced under the 2017 Tax Cuts and Jobs Act (TCJA) 

• A discussion of the continuation and modification of the QOZ Rules under OB3 

• Potential tax planning strategies and special opportunities for taxpayers under the modified QOZ Rules 

• A comprehensive review of the Bonus Depreciation rules under TCJA  

• A discussion of the continuation and modification of the Bonus Depreciation Rules under OB3 

• Potential tax planning strategies related to the Bonus Depreciation Rules for domestic and foreign businesses looking to create or onshore business entities in the United States 

• A comprehensive review of the Qualified Small Business Stock (QSBS) Rules under TCJA 

• A discussion of the continuation and modification of the QSBS Rules under OB3 

• Potential tax planning strategies for United States C-Corporations under the QSBS Rules for 2025 and beyond 

• A discussion related to tax liability insurance and how this may be utilized for uncertain tax positions related to QSBS  

Learn more about Austin C. Carlson: 

• Visit the News & Resources page on Gray Reed’s website: https://www.grayreed.com/NewsResources 

• View Austin C. Carlson’s profile on Gray Reed’s website: https://www.grayreed.com/Our-People/Austin-C-Carlson 

• Connect with Austin C. Carlson on LinkedIn: https://www.linkedin.com/in/austin-carlson-jd-cpa-63031029/ 

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

• Visit Gray Reed’s YouTube Channel: https://www.youtube.com/@GrayReedLaw 

• Follow Gray Reed on Facebook: https://www.facebook.com/GrayReedLaw/ 

Further Resources: 

• OB3 - https://www.congress.gov/bill/119th-congress/house-bill/1/text 

• Tax Cuts and Jobs Act of 2017 - https://www.congress.gov/crs-product/R48485  

• QOZ IRCs - https://www.law.cornell.edu/uscode/text/26/subtitle-A/chapter-1/subchapter-Z 

• Map of QOZs: https://opportunityzones.com/location/ 

• IRC 179 (bonus depreciation) - https://www.law.cornell.edu/uscode/text/26/179 

• IRC 1202 (QSBS) - https://www.law.cornell.edu/uscode/text/26/1202  

• Tax Liability Insurance - https://www.aon.com/apac/transaction-liability/tax-insurance.jsp  

*********************************** 

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 makes 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: 

•  YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc 

•  Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa 

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 5 

In this episode of The Essential Tax Podcast, Mishkin presents and analyzes a brief history and some significant tax provisions of the One Big Beautiful Bill Act (OB3) that was recently signed into law by President Trump. 

Tune in for these key takeaways: 

• A discussion of widely publicized provisions that may have been expected, but were ultimately not included in the bill, such as the Trump Gold Card (tax treatment of certain international entrepreneurs) 

• Important changes to the standard deduction and the state and local tax (SALT) deduction 

• Changes to Charitable deduction rules and requirements 

• Details of the “no tax on tips” rules, including a definition of qualified tips, phase out amounts, limitations, and time restrictions to utilize this provision 

• An explanation of the new deduction for overtime pay and recommendations for specific filing statuses to maximize its benefit 

• Changes to IRC 529 plans and what to know about the new Trump Accounts (fka MAGA Accounts) 

• Important information about the extension and modification of limitation on gambling and wagering losses, including an explanation of the changes in session netting 

• Details about the extension of the TCJA gift and estate tax exemption 

• Important changes made by OB3 regarding business entity types, and which ones to utilize when setting up a new business 

• A discussion of the continuation and modification of the Bonus Depreciation Rules and qualified business income deduction under OB3 

• A discussion of the continuation and modification of the qualified small business stock (QSBS) rules under OB3 

• An overview of the continuation and modification of the qualified opportunity zone (QOZ) rules under OB3 

• OB3’s termination of many energy credits and how to maximize deductions before the changes take effect 

• Relevant information about Congress’s technical correction of the error in the TCJA downward attribution of stock ownership 

• Changes to certain provisions and limitations relating to remittance transfer tax 

• Recent changes to IRS staffing and how it may affect tax processing and response times 

Further Resources: 

• OB3 - https://www.congress.gov/bill/119th-congress/house-bill/1/text 

• Tax Cuts and Jobs Act of 2017 - https://www.congress.gov/crs-product/R48485  

• QOZ IRCs - https://www.law.cornell.edu/uscode/text/26/subtitle-A/chapter-1/subchapter-Z 

• Map of QOZs: https://opportunityzones.com/location/ 

• IRC 179 (bonus depreciation) - https://www.law.cornell.edu/uscode/text/26/179 

• IRC 1202 (QSBS) - https://www.law.cornell.edu/uscode/text/26/1202  

• Tax Liability Insurance - https://www.aon.com/apac/transaction-liability/tax-insurance.jsp  

• CIV Enforcement Memo Re Denaturalization: https://www.justice.gov/civil/media/1404046/dl?inline 

*********************************** 

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 makes 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:  

•  YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc 

•  Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa 

Tune in to this mini episode of The Essential Tax Podcast for practical tips and updates on a timely topic in the international tax realm. Your host, Mishkin Santa, will briefly guide you through the most up-to-date information on this hot tax topic as well as provide his invaluable analysis and expert recommendations. 

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 makes 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: 

 * YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc 

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

Tune in to this mini episode of The Essential Tax Podcast for practical tips and updates on a timely topic in the international tax realm. Your host, Mishkin Santa, will briefly guide you through the most up-to-date information on this hot tax topic as well as provide his invaluable analysis and expert recommendations.

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 makes 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: 

 * YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc 

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

Tune in to this mini episode of The Essential Tax Podcast for practical tips and updates on a timely topic in the international tax realm. Your host, Mishkin Santa, will briefly guide you through the most up-to-date information on this hot tax topic as well as provide his invaluable analysis and expert recommendations.

i. June 10th TIGTA Report: https://www.tigta.gov/sites/default/files/reports/2025-06/2025400026fr.pdf

ii. IRS Website for Amended Tax Returns: https://www.irs.gov/filing/wheres-my-amended-return

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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 4

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Eleni Drakou, Partner at Michael Kyprianou Law Firm, Limassol, Cyprus. Eleni holds a law degree from the Aristotle University of Thessaloniki in Greece and a master’s degree in management (MA) from the University of Wolverhampton Business School in the United Kingdom. Eleni specializes in immovable property law and has extensive immigration law experience. Her practice focuses on strategic planning for business growth in Cyprus and abroad.

Eleni and Mishkin discuss general Cyprus tax and immigration laws, the status of residency by investment and other beneficial tax programs in Cyprus, an overview of Cyprus entities and trusts, and more.

Tune in for these key takeaways:

• Information about the Cyprus 183-day and 60-day tax residency rules

• Details about the new Cypriot Center of Business Interest rule, to be implemented in 2026

• Cyprus income tax rates and reporting requirements

• Cyprus tax exemptions and benefits for non-domiciled individuals

• Details on the upcoming Cyprus tax reform initiatives and associated updates to the Cyprus tax code coming in early 2026

• Available Cyprus Ministry of Finance tax deductions for charitable contributions, home loans, dependents, and rental payments

• Cypriot Wealth and special assessment taxes for immigrating individuals

• Details about the Cyprus Investment Promotion Agency

• Suspension of the Cyprus Citizenship by Investment (CBI) Program and replacement with other paths to naturalization

• How the US Controlled Foreign Corporation (CFC), Foreign Grantor/Non-Grantor Trust, Passive Foreign Investment Company (PFIC), and Foreign Financial Asset reporting rules apply to various aspects of Cyprus financial assets, investments, and entities

• The transition from temporary to permanent tax residency in Cyprus

• Cyprus’s Requirements for reporting worldwide income

• Requirements, purposes, and benefits of establishing a business entity or trust in Cyprus

• Current and potential future Cyprus tax rates for business entities and trusts

Learn more about Eleni Drakou:

• Visit the About page on Michael Kyprianou Law Firm’s website: https://www.kyprianou.com/about/

• View Eleni’s profile on Michael Kyprianou Law Firm’s website: https://www.kyprianou.com/key_contact/eleni-drakou/

• Connect with Eleni on LinkedIn: https://www.linkedin.com/in/elenidrakou/

• Follow Michael Kyprianou Law Firm on LinkedIn: https://www.linkedin.com/company/m-kyprianou-llc/

• Visit Michael Kyprianou Advocates’ YouTube Channel: https://www.youtube.com/channel/UCzOqshpyMFb7nk3EKZeHlWw/videos

• Follow Michael Kyprianou Law Firm on Facebook: https://www.facebook.com/MiKyprianou

***********************************

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 makes 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:

• * YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 3

In this episode of The Essential Tax Podcast, Mishkin Santa visits with attorney Becki L. Young, Partner, Grossman Young & Hammond. Becki was recently recognized by Business Today as one of the Top 10 Most Influential Business Lawyers in the USA. Mishkin and Becki discuss US immigration policies as they relate to incoming foreign nationals and outgoing American citizens. They also discuss current events in the US immigration sphere.

Tune in for these key takeaways:

• Types of US Immigrant Visas (Green Card, EB Visas)

• Types of US-Non-Immigrant Visas (A, G1-G5 (plus NATO), H1B, F, J, L, M, and O)

• US Visa Wait & Processing Times, Priority Dates, and Best Practices

• The US Department of State’s Visa Bulletin

• Differences in US Tax Treatment by Visa Type

• Challenges of Leaving and/or Re-Entering the US as a Foreign Person

• Changes that the Current US Political Administration Has Brought to the Visa Process
• G28 (Notice of Representation) and How it Can Help During the Immigration Process

• Status of the New US Gold Card Program

• The Process & Timeline for Conversion of Temporary Visa to Green Card

• How the Substantial Presence Test Applies to Various Visa Types

• The Proposed Excise Tax (Remittance Transfer) on Outbound US Monetary Transfers

• The Status of the Current Birthright Citizenship Case in SCOTUS

• The IRC 7345 Limit and How it Can Affect Passport Status

Learn more about Becki L. Young:

• Visit the Resources page on Grossman Young & Hammond’s website: https://www.grossmanyoung.com/resources/

• View Becki’s profile on Grossman Young & Hammond’s website: https://www.grossmanyoung.com/attorneys/becki-young/

• Connect with Becki on LinkedIn: https://www.linkedin.com/in/blyimmigration/

• Follow Grossman Young & Hammond, LLC on LinkedIn: https://www.linkedin.com/company/grossmanyoung/

• Visit Grossman Young & Hammond’s YouTube Channel: https://www.youtube.com/@grossmanyounghammondllc73

• Follow Grossman Young & Hammond, LLC on Facebook: https://www.facebook.com/grossmanyoung/

Further Resources:

• The Visa Bulletin: http://travel.state.gov/content/travel/en/legal/visa-law0/visa-bulletin.html

• Grossman Young & Hammond Website: https://www.grossmanyoung.com/

• The Visa Bulletin: https://travel.state.gov/content/travel/en/legal/visa-law0/visa-bulletin.html

• Third Party Calculators: https://www.mygcvisa.com/calculator/

• Processing Times: https://egov.uscis.gov/processing-times/

• E Visa Treaty Countries: https://travel.state.gov/content/travel/en/us-visas/visa-information-resources/fees/treaty.html

• Gold Card: Trumpcard.gov

• Gold Card Forbes Article: https://www.forbes.com/sites/suzannerowankelleher/2025/05/29/why-trumps-gold-card-visa-may-never-happen-math-does-not-add-up-expert-says/

• IRC 7345: https://www.law.cornell.edu/uscode/text/26/7345

***********************************

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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 2 - 2025 US-Australia Cross-Border Tax Update with Tom Howard of Pilot Partners

In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Tom Howard, CA, Associate Director of Taxation Advisory at Pilot Chartered Accountants in Brisbane, Queensland, Australia. In this episode, Tom and Mishkin dive into the intricacies of Australian Superannuation, particularly focusing on self-managed super funds (SMSFs) and how they compare to U.S. retirement structures like Roth IRAs and 401(k) plans.

Tune in for these key takeaways:

• The basics of Australian Superannuation—a protected, tax-advantaged retirement savings vehicle

• The flexibility and appeal of Self-Managed Super Funds (SMSFs) for family groups with significant wealth

• Tax benefits of contributing to Australian Superannuation

• The impact of capital gains tax on property investments within SMSFs

• Regulatory limitations on Australian Super contributions

• Challenges for U.S. taxpayers with Australian Super funds

• Complications arising when Australians use their SMSFs to invest in U.S. real estate, including FIRPTA withholding on sales and potential U.S. tax compliance issues

• The process for obtaining rulings from the Australian Tax Office (ATO)

• Some differences between Australia’s private ruling process (no ATO fee) and the U.S. IRS (high fees for private rulings).

Learn more about Tom Howard:

• Visit the Services page on Pilot Partners’ website: https://www.pilotpartners.com.au/services/

• View Tom’s profile on Pilot Partners’ website: https://www.pilotpartners.com.au/people/thomas-howard/

• Connect with Tom on LinkedIn: https://www.linkedin.com/in/tom-howard-231136116/?originalSubdomain=au

• Follow Pilot Partners on LinkedIn: https://www.linkedin.com/company/pilot-partners/

• Visit Pilot Partners’ YouTube Channel: https://www.youtube.com/channel/UCJDG2Jpwm0zy4HsNWtwP2eA

• Follow Pilot Partners on Facebook: https://www.facebook.com/pilotpartners

Further Resources:

• Pilot Partners: https://www.pilotpartners.com.au/

• Form 3520: https://www.irs.gov/forms-pubs/about-form-3520

• Form 3520-A: https://www.irs.gov/forms-pubs/about-form-3520-a

• TWG Foreign Pension Blog Post: https://thewolfgroup.com/blog/proposed-regulations-issued-in-2024-affect-your-options-for-foreign-pension-reporting/

• Form 5471: https://www.irs.gov/forms-pubs/about-form-5471

• Form 8992: https://www.irs.gov/forms-pubs/about-form-8992

• Form 1116: https://www.irs.gov/pub/irs-pdf/f1116.pdf

• Instructions to Form 1116: https://www.irs.gov/instructions/i1116

***********************************

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 makes 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:

• YouTube: 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 on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc

• Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa