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Hi I'm Anthony parent of IRS medic parent & parent LLP and today I have Robert Hanssen our lead international attorney joining us to go over some of the subpart F changes that occurred in our lovely tax reform right and remember this this was a went in June when I think they rolled out the postcard the the tax reform on the postcard and right that was one of the I was laughing at the point I said there's just no way I can believe in lower rates right but what I can't believe is a simpler tax code cuz that's just sort of impossible and as we saw it play out it didn't get more simple and let's just go what is subpart F let's just give a little refresher for those of us who might not sure so subpart F is the part of the tax code that creates a kind of deemed income for people who majority owned or have majority u.s. person owned foreign companies foreign corporations in specific and so you might not be receiving a dividend from your foreign company but depending on what type of activity that the company is in you might be said to have received income so you might get an extra bit of income and extra tax that you're not really expecting okay so what so Part F is doing it's saying that hey I didn't take any I didn't get any money from this business but the business made money and they're like well you should have taken it I guess right I think it's I think it's envisioned to be some type of anti-abuse rule because the kind of activities that that we're creating subpart F for are the kind of activities where people might do some shenanigans possibly right so we're gonna hit everyone with a subpart F income so even if your company isn't doing shenanigans or let's just say no you didn't realize that you're worldwide income was was taxable because it's maybe something that you left and let's just say India or the or the UK or whatever it is and it's oh no it's all just UK source income I pay taxes on the UK and isn't there a treaty that takes care of something like that double taxation treaty and so the treaties usually don't help out really not really no one that statements calls for individuals not not much help at all for companies who can really take advantage of the multi-jurisdictional a bill parts of the treaty yeah they can they can get much more benefit but individuals is much harder yeah and just to give you a recap of how it works is when you're when you're an individual you are a US person and you can go become you know a Danish citizen to or whatever it is but also in your u.s. person so you can't shift your jurisdiction out of the US but