
Woodpoint Capital: 2020 Investment Letter
The recession debate: A recession occurs on average every seven years. But in the US, the bull market is roaring into its 11th... Read more

Is your Australian related party loan “debt” or “equity” for US tax purposes?
If you are attempting to determine how your related party loan could characterized for US tax purposes, there are a number of considerations... Read more

Is your Australian trust a “grantor trust” for US tax purposes?
The US taxes a “United States Person” (defined to include a ‘US resident’ or a citizen) on a worldwide basis, whereas non-US persons... Read more

A nonresident individual married to a U.S. citizen may be required to file a U.S. tax return if…
Generally, the number of days an individual spends in a country is one of the important determinants of taxability in such country. But... Read more

The 2019 OECD Tax Statistics – how does the US and Australia compare?
The OECD has released its annual Revenue Statistics Report comparing the tax data for all OECD countries . The OECD Tax Statistics The... Read more

Rules of POEM – Part II
An earlier blog on POEM started with a discussion on the determinants of residential status of a foreign corporation in India. The Indian... Read more