User talk:Guya

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Muchas gracias!

Thank you for your input on the foreign source military pension!


Transfer pricing?

Just a question; thanks Guya for your input :)

Why would transfer pricing be an issue with the non-US source foreign individuals question? I know it is definitely a factor when dealing with income in the US from foreign sources and the pricing methodology used, but I was unaware of this being needed for non-US source income?

Thanks again!!!


Hiya David!


Hi David. -- lizzit

ITIN for Non Resident Alien owning a single member LLC

Hi Guya,

Would like to get in touch with you if possible to further discuss a point raised in this thread:

More specifically, the comment about how an individual qualifies for an ITIN since he owns an LLC which could generate income subject to US withholding.

I'm currently trying to fill in the W7 form and need some advice/counsel on how to do this for my situation (i.e. which reason/exception applies to me and what other forms I need to fill out.

Would appreciate any help you have to offer even if it is to just refer me to a resource or professional service that will assist me with this.

My email is:

Thank you. Jason


Hi Guya, Could you help me with my case?

Taxpayer wants to know if it is optional to claim the exclusion in 20008.

Thank you in advance. Glory4ever 18:22, 8 February 2009 (CST)

NRA to NRA query

Would appreciate with some leads on the following case :

Facts: 1)H, is a NRA, married to W, also an NRA .(Non-Treaty domiciled in community) 2)H and W own a joint bank account in the State of NYK with Rights of Survival. 3)H and W own a joint broker account in the State of NYK with right of survival 4)H is the sole contributor to the NYK bank account by way of his employer directly transfering the funds to the Joint account (employment not connected with a trade/business in the US). 5)H is the sole contributor to the NYK broker account by way of receiving US shares from his employer(employment not connected with a trade/business in the US)

Questions : 1.Would H’s contribution to the joint bank account be defined as "intangible assets" ? 2 Would H’s contribution to the joint broker account be defined as intangible asset ? 3.Are there any gift tax implications on the incoming funds/shares ? 4.Are there any gift tax implications if the couple wire funds (not shares)from their joint US bank or joint US Broker to a joint account outside the US ? 5.Are there any gift tax implications if the couple wire funds to separate accounts outside the US.

Thank you . Paris Paris 13:14, 17 May 2009 (CDT)

State Impact on Voluntary Disclosure

Do you know what CA law is with regard to the Federal Disclosure liency program? Other states?

Thanks, John Blecka, CPA

Prior Year FBAR Filings

Hi Guya, Can you please expand on your 18 July 2009 response on Discussion: Prior Year FBAR Filings. I posted a few questions I had. I need to understand the pros and cons of voluntary disclosure vs. quiet disclosure and like to understand why you recommend quiet disclosure. Thank you for your help, Jay

Foreign Mortgage Currency Gain - Passive or General?

Guya - I have been reading your advice on a few discussion threads regarding the foreign mortgage currency gain. I have worked at both KPMG and PwC over the last 15 years and they had very different views as to whether this gain was general limitation (KPMG) or passive (PwC). I was wondering what your thoughts were on this point?

NI Rebates

Hello Guya, I have a question for you, and I hope you can point me to the right source. Do you know if the NI rebates from HRMC should be taxable for US tax purposes in the year rebated, or should they be treated as quasi IRA/401(k) tax deferred contributions? Personal taxation is not my forte, and I have never fully researched the issue before. Any help would be greatly appreciated. Cheers - Foxtron

RE: Foreign mutual fund investments - UBS account

Hello Guya,

Thank you for your input. It appears that you are very knowledgeable in foreign investments. I have just this one client that I need to help amending his tax returns to report this foreign account. I would like to use your services to avoid any errors. If interested please let me know and give me an idea about your fee so I can discuss it with the client before committing. Thanks and I look forward to hearing from you. Please respond to Fa740 20:45, 26 May 2010 (CDT)

H1B ?

Hi Guya -

I am getting ready to file the H1B Visa client I spoke to you about months ago and have just a few questions that I hope you can help me with.

My client is on an H1B since October of 2009 through today. I calcualted the SPT to be May 23, 2010 to file as a resident alien, allowing him to take the exemption for his wife (H4) and son in addition to a FTHB credit for his first home owned in the US.

Client just filed his last 2009 Portugese tax return. Can I take a deduction for any of his expnses, such as mortgage interest paid there, medical, etc? I am thinking the answer is no, but I want to make sure. I do believe I can take his unreimbursed moving expenses and possibly his health insurance as an independent contractor. TP also has rental income and Portuguese income which I know I need to report (worlwide income), but then I can take a 1116 for the amount of Portugese tax wihheld on his pay?

Only other items are day care expenses and his US w-2.

My question lies with the two piggyback elections. Is this just a memo, written by me that explains the elections we are requesting which then is sign by the TP and his spouse?

I really do apprecaite you time.

CLient does maintain a tiny checking account in Portugese, which I will need to disclose.

Jeff-Ohio 11:21, 27 May 2010 (CDT)

First Time Filing in US

Hi Guya:

Thank you for your help with two of my clients from the UK. Is it possible that you could email me? I have questions about filing the return in the UK. <> Thanks, Bell

First time filing in US

Hi Guya: Thank you so much for your help with my client from the UK. Would it be possible for me to email you privately? My email is

OVDI 2011 and opting out..


I am based in California and filed my papers for OVDI 2011. My situation has to do with assets in India that I inherited and was not repatriable to the US. None of the income was generated in the US and taxes were being filed in India.

I did file under OVDI 2011 (paid penalties and past taxes thus far) and am considering if opting out makes sense.

Would like to know if you are available for consultation. Please email me at


Badjate 01:01, 22 December 2011 (UTC)



I was contacted by a UK citizen needing to file US taxes. If you're interested, can you send me your contact info? Or recommend someone else?


Canadian citizen thread

Hi Guya,

Thank you for your post on the Discussion:Canadian_citizen_never_reported_US_rental_income thread. I would like to refer my client's cousin & sister to a tax pro that can handle both their US & Canada issues. Do you handle this kind of thing? Or do you have a referral that you can pass along to me?

Thank you for your help!

--Wiles 17:38, 31 January 2013 (UTC)


Hi Guya, you recently replied to my post- Amended return- US citizen living abroad. Will you be willing to consult with me for a fee? If so what would an half an hour of consult cost me? Could you please let me know. The client is from India and I do not think the US interest was added to income in India.

I have not taken this person as a client yet and am still weighing the pros and cons. I can fill the forms etc, but need to make sure I am doing the right thing. Please let me know if you are available for a consultation. My email is Thanks

15:19, 19 May 2013 User:Krishsvasan

Australian Superannuation


You provided me with some very helpful information regarding the lady with the Australian Superannuation, and the FBAR,3520, and 3520-A requirements.

I checked with her and have some additional information. I'm don't know if it matters, but wanted to make sure all the facts were accurate.

She actually worked for a couple of employers in Australia. With one of them, the employer contributed 14% of salary and she contributed 7% of salary, with the other, the employer contributed 9% and she thinks she contributed 5 or 6%.

Before she left Australia she rolled both of those plans over into the plan she is in now.

Will this have any impact as to whether IRS Regulation 1.402(b)-1(b)(6) covers her plan and whether the 3520 and 3520-A will need to be filed?

Thanks very much for your input. DannyAlBe 16:18, 28 May 2013 (UTC)

HMRC certificate of coverage

Hello Guya. I am following up on your comment regarding a client obtaining a certificate of NIC coverage from the HMRC to attach to the return so he does not have the IRS asking for SE tax. Can I refer the client to you for assistance with this matter?

Dependent deduction

Hello Guya. I have been dealing with a tax return for some time and it's time to finish it. I am asking you because you have been most helpful in this forum and your opinion is highly regarded in foreign tax issues.

My clients have been resident aliens (not citizens) for years and left the country for good in mid-2012 (they lived in the US for 193 days in 2012). Reading the Pub 519 I see they have the option of filing dual-status or 1040 reporting world-wide income. I think is more beneficial if they file 1040 return because the foreign income is not too high and the foreign taxes paid are considerable. My question is regarding the children dependency deduction. One child was born in the USA, but not the other one. Is it possible to take both kids as dependents, or they can only take the one who is a citizen. My concern is that the other kid wasn't citizen or resident at the end of 2012. I think they can because Pub 501 states "Child's place of residence. Children usually are citizens or residents of the country of their parents".

Thank you so much for your help. Lalva 19:26, 30 July 2013 (UTC)


Guya, did you have experience in this topic, can you offer a consultation?

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