1 PART OF THE LEHMAN TAX LAW KNOWLEDGE BASE SERIES United States Taxation Of Investors U.S. Taxation of Foreign Investors Non Resident Alien Individuals & Foreign Corporations By Richard S. Lehman Esq. TAX ATTORNEY
2 Richard S. Lehman Esq. Masters in Tax Law from New York University Law School Four years of U.S. Tax Court and Internal Revenue Service experience in Washington D.C. Richard Lehman regularly works with law firms, accountants, businesses and individuals struggling to find their way through the complexities of the tax law. In short, Lehman is a valuable resource to each of these audiences. With over 38 years as a tax lawyer in Florida, Lehman has built a national reputation for being able to handle the toughest tax cases, structure the most sophisticated income tax and estate tax plans, and defend clients before the IRS. Over 38 years of Florida real estate experience with foreign investors that purchase: shopping centers rental apartments rental apartment houses warehouses land acquisitions real estate development deals of all types Tel: (561) Skype: LehmanTaxLaw
3 Define The Foreign Investor Non Resident Alien Individual A non U.S. citizen individual who is NOT a Resident Alien NOTE: Resident Alien (Resident for U.S. Income Tax Purposes) Foreign Corporations A Foreign Corporation is any corporation that is not formed in the United States or under the laws of the United States or any state.
4 TAXATION PATTERN U.S. Resident Alien ("Tax Resident") - Subject to Taxation 1. Income Taxation - Worldwide Income 2. Estate Taxation - Worldwide Assets 3. Gift Taxation - Worldwide Assets
5 Non Resident Alien Individual Investor Subject to Taxation 1. Income Taxation - United States source income, limited type of foreign Source income 2. Estate Tax - United States Situs assets only (includes real estate) 3. Gift Tax - real and tangible personal property with a United States Situs **Branch Tax - Corporations only
6 STATUS FOR TAX PURPOSES A. Non-Resident Alien - Not a Resident Alien B. Resident for Income Tax Purposes 1. Green Card 2. Substantial Presence Test 3. Voluntary Election Exceptions: 4. The Closer Connection 5. Treaties: Tie Breaker C. Foreign Corporations
7 Substantial Presence Test
8 EXCEPTIONAL CIRCUMSTANCES AND SPECIAL BENEFITS Students A foreign student who has obtained the proper immigration status will be exempt from being treated as a U.S. resident for U.S. tax purposes even if he or she is here for a substantial time period that would originally result in the student being taxed as a U.S. resident. This student visa not only permits the student to study in the United States, but to pay taxes only on income from U.S. sources not worldwide income. The visa also permits the student's direct relatives to accompany the student to the United States and receive the same tax benefits.
9 TWO TYPES OF FEDERAL INCOME TAXATION PATTERNS Foreign Taxpayer Foreign Investors (both Alien Individuals and Foreign Corporations) pay U.S. tax on U.S. income in two entirely different ways depending upon whether the income the Foreign Taxpayer earns is from "passive" sources or whether the income results from the Foreign Taxpayer's conduct of an active trade or business in the U.S. Source of Income Rules 1. U.S. Source Income 2. Foreign Source Income 3. Deductions Taxation of Passive (Non Business Income) 1. 30% Flat Tax Rate - Gross Income 2. Withholding Obligations and Contingency Taxation of Active Trade or Business Income 1. Graduated Corporate Tax Rates 2. Graduated Income Tax Rates 3. Effectively Connected Income 4. Income Effectively Connected with a U.S. Business Treaties
10 SEVERAL IMPORTANT EXCEPTIONS Capital Gains Taxation Alien Individual = individual tax rates and generally no tax on capital gains Foreign Corporation = corporate tax rates and generally no tax on capital gains Estate Taxation 1. Alien Individual - Residency for Estate Tax Purposes 2. Non Resident Tax Rates U.S. Real Property 1. U.S. companies holding U.S.Real Property and the U.S. Estate and Gift taxes The Branch Profits Tax (Foreign Corporation Only) Foreign Corporation 1. U.S. Trade or Business 2. Foreign Source Income
11 Unlike a Foreign Taxpayer that is taxed on passive U.S. source income only Income of a Foreign Taxpayer that conducts a trade or business in the U.S. will pay tax on all of its United States source income and in limited circumstances, U.S. tax must be paid on income that is earned from foreign sources and not U.S. sources. Foreign source income that is attributable to a Foreign Taxpayer's U.S. trade or business activity may be taxed by the U.S. and is called "Effectively Connected Income".
12 Source of Income Rules a. U.S. Source Income b. Foreign Source Income c. Deductions There are a strict set of rules that govern the determination of whether income finds its source in the United States or a foreign place for U.S. tax purposes.
13 Source of Income 1. Compensation for personal services. The source of income from the personal services is located at the place where the services are performed. 2. Rents and Royalties: Rent or royalty income has its source at the location, or place of use, of the leased or licensed property. 3. Real Properly Income and Gain: Income and gain from the rental or sale of real estate has its source at the place where the property is situated. 4. Sale of Personal Property: Historically, gain from the sale of personal property has been sourced at the place of sale which is generally held to be the place where title to the goods passes; however, the rules have become more complex taking other factors in place.
14 Source of Income 5. Interest. The source of interest income is generally determined by reference to the residence of the debtor; interest paid by a resident of the United States constitutes U.S. source income, while interest paid by foreign residents is generally foreign-source income. 6. Dividends. The source of dividend income generally depends on the nationality or place of incorporation of the corporate payer; that is, distributions by U.S. corporations constitute domestic-source income, while dividends of foreign corporations are foreign-source income. There are, however, several important exceptions to these rules.
15 Source of Income 7. Partially Within and Partially Without. There is a set of source rules that consider the sources of income that can be partially earned in the U.S. and partially from foreign sources such as income from transportation services rendered partly within and partly without the United States; income from the sale of inventory property "produced", "created", "fabricated", "manufactured", "extracted", "preserved", "cured", or "aged" without and sold within the United States or vice versa, and several other types of income. Generally, this is done on some type of allocation basis between the source countries.
16 Source of Deductions The source rules for deductions are considerably less specific than those dealing with gross income. The rules regarding claiming deductions against U.S. income earned by a Foreign Taxpayer merely provide that taxable income from domestic or foreign sources is to be determined by properly apportioning or allocating expenses, losses, and other deductions to the items of gross income to which they relate.
17 THE EFFECT OF BILATERAL TREATIES - EXTREMELY IMPORTANT BENEFITS Tax treaties between the U.S. and other countries can operate to; 1. reduce (or even eliminate) the rate of U.S. tax on certain types of U.S. income derived by Foreign Taxpayers situated in the treatypartner country; 2. override various statutory source of income rules 3. exempt certain types of income or activities from taxation, by one or both treaty-partner countries; and 4. extend credit for taxes levied by one country to situations where the domestic law would not so provide.
18 SUMMARY DEFINING THE FOREIGN INVESTOR-INCOME TAX PURPOSES Non Resident Alien Individual Foreign Corporation TWO TYPES OF TAXATION U.S. Source Income Active Business Income Passive Income EFFECT OF TAX TREATIES EXCEPTIONS TO THE RULES REAL ESTАТЕ EFFECTIVELУ CONNECTED INCOME BRANCH TAX
19 THE BRANCH PROFITS TAX A tax on Foreign Corporations (generally not treaty corporations) that taxes the annual un-invested cash of a foreign corporation that represents earnings and profits. Foreign Corporation Net profit Before U.S. Taxes $1,000,000 3% City Income Tax (30,000) 5% State Income Tax (48,500) 34% Federal Income Tax (321,500) 30% U.S. Branch Tax (180,000) NET PROFITS $ 420,000 (CORPORATE EXAMPLE)
20 Investing in U.S. Real Estate Because the way in which Non Resident Aliens of Foreign Corporations passive income is treated by the U.S., the U.S. has had to devise a system to be able to assert its taxation on U.S. source income where they had no jurisdiction to tax the recipient. Generally, in the case of passive capital gains caused by a Non Resident Alien or Foreign Corporation, there is no taxation. Therefore, there was no need to devise a taxing structure this is not the case for Foreign Investors that invest in U.S. real estate or Foreign Investors that are not governed by "gains income" tax treaty and have "effectively connected capital gains income".
21 Practical Advice 1. Excellent time because dollar borrowing is cheap for strong investors. There is cheap money if you are strong. 2. Investment from Russia, China, Brazil, India, Israel, South Korea, Canada investment is strong because people are making money. 3. Investment is strong from Venezuela, Spain, and Latin America in general. These people are some of the people investing in America because they are afraid. 4. England, France, Germany, Netherlands, Belgium, Italy have always been investors in America and now investing in real estate in Europe where the shaky Euro prevails is certainly not the place to be.
22 Practical Advice One client leads to another. If you do the right job as a professional, it works. If you do not, it does not work. Real Estate Attorney Tax Attorney Accountant Real Estate Broker(s) Appraisers Any missing link spells the end if it is early in the relationship. A deal gone bad in Florida for someone who needs to fly in from New York for a day to fix it is allot different than a deal gone bad for a person who comes from Mumbai.
23 Taxation of Real Estate History Historical discussion until the mid 80's, N.V. corporations. Real Estate has its own Code Section separate apart from income and gains and losses from other kinds of income. Basically, U.S. wants to have at least one tax. However, if you do not know what you are doing you can pay three taxes. If you really know what you are doing and the circumstances are right you can cut the normal tax an American would pay in half.
24 Potential Taxes What are the taxes a foreign investor can be subject to? Tax planning for foreign investors' real estate requires a look at both the U.S. income tax consequences and U.S. estate and gift tax consequences and in the case of the foreign corporate investor, potential dividend taxes and a United States "branch tax". Often it means looking at the taxes in the Investor's home country to avoid double taxation.
25 Income Tax - Annual Income There is a U.S. income tax that is applied on annual net income which starts at 15% and can be as high as 35% for both corporations and individuals. There is a tax on capital gains from the sale of assets which is only 15% to an individual taxpayer, but may be as high as 35% to a corporate taxpayer.
26 Estate Tax There is an estate tax when a non resident alien individual dies owning U.S. real estate of shares of certain types of entities that own U.S. real estate. Unlike Americans who get huge deductions in calculating their Estate tax, the first $60,000 of value is excluded. Thereafter this estate tax can be as high as 35% of the equity value of the real estate. Gift Tax There is also a gift tax if a non resident alien individual gifts U.S. real estate to a third party. This can be as high as the estate tax, depending upon the value of the gift.
27 Definition of Domicile A person acquires a domicile in a place by living there, for even a brief period of time, with no definite present intention of later removing there form. Residence without the requisite intention to remain indefinitely will not suffice to constitute domicile, nor will intention to change domicile effect such a change unless accompanied by actual removal.
28 The Branch Profits Tax There is an additional tax that foreign corporations must be aware of. This is a major trap for the unwary. Absent the tax benefits of an applicable United States tax treaty; a Foreign Corporation may be subject to not only two combined State and Federal income tax approaching 50%; but depending upon the facts and circumstances, foreign corporations with earning from United States investment could be subject to an additional United States tax known as the Branch Profits tax. The 30% tax is applied to U.S. income that is either not distributed as a dividend or reinvested in U.S. assets by the Foreign Corporation.
29 PART OF THE United States Taxation of Foreign Investors There are a multiplicity of tax strategies that can be used to make the most of all worlds. NUMEROUS TYPES OF OWNERSHIP (ENTITIES) FOR THE OWNERSHIP OF U.S. REAL ESTATE. ALL MUST BE TAILOR MADE TO FIT THE INVESTORS
30 Available Entities
31 Available Entities
32 Available Entities
33 Available Entities
34 Available Entities
35 Available Entities
36 Available Entities
37 Available Entities
38 The Individual Foreign Investor The Problem of the Estate Tax There are many exceptions to this general rule but it is still the general rule. The United Sates Estate tax is so onerous that the individual Foreign Investor will generally not want to assume the risk of his or her estate having to pay the United States a large tax on the death of the individual foreign owner. As a general rule, the individual foreign investor that invest in United States real estate in equity amounts of $1,000,000 or more is going to be forced to use a corporation formed outside of the United States (Foreign Corporations) somewhere in their investment structure if they are going to avoid the U.S. estate tax.
39 The Individual Foreign Investor - The Problem of the Estate Tax The Estate tax may not be a factor if one of the exceptions applies. For example, if the Foreign Investor is from a country with whom the United States has an Estate Tax Treaty, the U.S. estate tax may not apply to that foreign individual. If the individual Foreign Investor is from a country that has its own high estate tax, then the U.S. estate tax may not be of concern because it can be credited against the Foreign Investor's estate tax to his or her own country, so that there is no double estate tax.
40 Tax Planning Opportunities Corporate Liquidations The principal tax planning tool of the use of the Foreign Corporation that owns a U.S. corporation to own its U.S. real estate is to make sure that when the United States real estate is sold by the U.S. Corporation, that U.S. Corporation must be liquidated after the sale. In this fashion only one single U.S. tax is paid at the U.S. corporation level. The proceeds of sale may be transferred free of tax by the U.S. corporation after it has paid its U.S. tax if it is liquidating after the sale. Often one Foreign Corporation may be used as a holding company and will set up several U.S. corporations to own different projects. That way each U.S. Corporation may be liquidated on a deal by deal basis, leaving the Foreign corporation in place.
41 Corporate Liquidation Step 2 on chart below reflects the tax effects of liquidation. Step 3 reflects the tax effects of continuing the company's business.
42 Portfolio Loans Another often used tax planning tool is known as the "Portfolio Loan". As a general rule a Foreign Corporation or a U.S. Corporation that owns U.S. real estate will be able to deduct as a business deduction all of the expenses of that ownership, which include the payment of interest on loans made to acquire the real estate. As a general rule, loans made by a Foreign Investor to his or her own Foreign Company, U.S. Company or Limited Liability Company will be deductible by the company. *** However, the payment of such interest to the Foreign Owner of the company may be subject to a tax as high as 30% on the gross interest paid to the investing company's foreign shareholder.
43 Portfolio Loans There is, however a major exception to this general rule provided in the Internal Revenue Code. That is that a Foreign Investor who owns less than 10% of the real estate investment will be able to receive the interest that is deductible by the Foreign Company free of any U.S. tax whatsoever. This rule does not work in the event the investor owns 10% or more of the real estate investment or the entity that owns that real estate investment. This less than 10% requirement includes interest in the deal owned by certain relatives or related companies of the Taxpayer
44 Portfolio Loans Exclusion for interest paid to Foreign Investors. This can be accomplished at the actual time of sale by a Foreign Investor of his or her U.S. investment. To understand this, it is important to keep in mind that the portfolio interest deduction and exclusion from income is only appropriate if the Foreign Investor no longer has a 10% or less interest in the property.
45 Portfolio Loans A Foreign Seller may wish to sell the property, not for all cash but rather for cash and the balance due in the form of a note payable by the U.S. Buyer to the Foreign Seller who no longer owns any part of the U.S. real estate. At that point the Foreign Seller will be receiving tax free interest from the note that the Foreign Seller holds as a result of the U.S. real estate and the property can be used to secure the note until its full payment. This method of converting what otherwise might be taxable sales proceeds into tax free interest income could be of significant tax value under the right circumstances.
47 Example of Portfolio Loan Sales
48 Like Kind Exchange Another method used by both Foreigners and Americans alike to grow their U.S. real estate portfolios free of U.S. tax is to make sure of the "Like Kind Exchange Rules". Essentially these rules hold that an investor in U.S. real estate may exchange the U.S. real estate project that they own for a different U.S. real estate project without paying any immediate tax of any gain or profit that may be accrued in the first investment.
49 Like Kind Exchange For example: A Brazilian investor owns a U.S. corporation which owns raw land that the investor purchased for $3 Million. Assume the raw land is now worth $6 Million and the investor wishes to terminate his investment in the raw land and instead own an income producing asst such as a shopping center. Assume the shopping center is worth $6. Even though the raw land has increased in the amount of $3 Million, none of that gain will be recognized or will it become taxable until the Corporation actually sells the real estate that it has acquired as part of the exchange. At that point the investor's investment in the shopping center has its original cost of $3 Million and any gain over and above that would be taxable if the shopping center were later sold.
50 Sale of Stock in a Foreign Corporation Theory is no U.S. Jurisdiction. Assume a Foreign Corporation owned by a Non Resident alien individual acquired a shopping center in the United States in 2000 for $10,000,000 and is selling it for $20,000,000, all cash in The tax on the gain is $3,350,000. Cash Distribution to Seller [$16,650,000]
51 Seller is Non Resident Alien
52 United States Buyer
53 TEN YEARS LATER
54 The Residency Starting Date 1. Green Card 2. Substantial Presence Income Tax Planning for a U.S. Taxpayer A. Foreign Businesses and Deferral w/15% Tax Rates B. U.S. Tool Capital Gains, Tax Free Investments C. Deferred Compensation Plans D. Personal Deductions
55 U.S. Situs Assets Any tangible and intangible property located in the United States at death Real estate located in the United States Generally shares of stock owned in United States corporations Generally partnership interests in U.S. assets Generally debt obligations of United States persons, states and governmental authorities * debt exceptions - do not include: bank deposits life insurance proceeds portfolio debt
56 Real Estate Tax Planning Tools 1) Liquidation of corporation after sale 2) The portfolio loan 3) Like kind exchanges 4) Sale of stock in foreign corporation
57 United States Taxation of Foreign Investors Richard S. Lehman, Esq S.W. 18th Street, Suite C-1 Boca Raton, FL Tel: Fax:
U.S. Taxation of Foreign Investors By Richard S. Lehman & Associates Attorneys at Law Copyright 2004 Copyright by Richard S. Lehman Page 1 U.S. Taxation of Foreign Corporations And Nonresident Aliens General
PART OF THE LEHMAN TAX LAW KNOWLEDGE BASE SERIES United States Taxation Of Investors Pre-Immigration Income Tax Planning By Richard S. Lehman Esq. TAX ATTORNEY www.lehmantaxlaw.com Richard S. Lehman Esq.
TAX PLANNING FOR THE FOREIGN REAL ESTATE INVESTOR Tax Benefits and Tax Traps By Richard S. Lehman & Associates Attorneys at Law TAX PLANNING FOR THE FOREIGN REAL ESTATE INVESTOR Tax Benefits and Tax Traps
U.S. Tax Benefits for Exporting By Richard S. Lehman, Esq. TAX ATTORNEY www.lehmantaxlaw.com Richard S. Lehman Esq. International Tax Attorney LehmanTaxLaw.com 6018 S.W. 18th Street, Suite C-1 Boca Raton,
Avoiding U.S. Investment Tax Traps Structuring Real Estate and Other Fund Investments Presented by: Joseph Gulant and Daniel Blickman Major Categories of Tax to Consider in Planning International Transactions
Pre-Immigration Tax Planning Safeguarding The Immigrant s Financial Interests Prior to Residency By Richard S. Lehman & Associates Attorneys at Law Pre-Immigration Tax Planning Safeguarding The Immigrant
Chapter 10 FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Daniel Cassidy 1 10.1 INTRODUCTION Foreign companies with U.S. business transactions face various layers of taxation. These include income, sales,
Foreign Person Investing in U.S. Real Estate Ian Shane Golenbock Eiseman Assor Bell & Peskoe LLP TTN New York Conference 2013 Foreign Purchases of U.S. Homes Foreign Home Buyers want to: Minimize tax on
INVESTMENT IN U.S. REAL ESTATE BY FOREIGN PERSONS Foreign investments in U.S. real estate, particularly in New York and Miami, have dramatically increased over the past several years and are expected to
U..S.. Tax Guiide for Non-Resiidents Table of Contents A. U.S. INCOME TAXES ON NON-RESIDENTS 1. Nonresident Alien or Resident Alien? o Nonresident Aliens o Resident Aliens Green Card Test Substantial Presence
FIRPTA requires that a buyer withhold 10% of the gross sales price, subject to certain exceptions, and send it to the Internal Revenue Service if the seller is a foreign person. U.S. Taxes Foreign investors
Description An LLC can only be formed by making appropriate filing with the state (see below). Owners are called members and the LLC may be managed by the members, similar to a partnership, or by managers
United States Estate and Gift MGI North America Taxation of the Executive summary The United States has unique estate and gift tax rules applicable to resident and nonresident aliens. A practitioner who
Estate Planning and Income Tax Issues for Nonresident Aliens Owning US Real Estate 1. Introductory Matters. Presented by Paul McCawley Greenberg Traurig, P.A. email@example.com 954.768.8269 October 24,
THOMAS WILLIAMS CPA, PLLC TO: OUR FRIENDS AND PROSPECTIVE CLIENTS FROM: THOMAS WILLIAMS, CPA RE: U.S. INCOME TAX ISSUES OF FOREIGN NATIONALS DATE: AS OF JANUARY 1, 2010 Dear Friends: The following is an
SHOULD MY BUSINESS BE AN S CORPORATION OR A LIMITED LIABILITY COMPANY? 2015 Keith J. Kanouse One Boca Place, Suite 324 Atrium 2255 Glades Road Boca Raton, Florida 33431 Telephone: (561) 451-8090 Fax: (561)
TAX ISSUES RAISED BY LNG PROJECTS Jon Lobb Baker Botts L.L.P. ABSTRACT This paper discusses tax issues that may be encountered by a company investing in an LNG project. 1. Income Taxes A seller's income
Coming to America U.S. Tax Planning for Foreign-Owned U.S. Operations September 2015 Table of Contents Introduction... 2 Tax Checklist for Foreign-Owned U.S. Operations... 2 Typical Life Cycle of Foreign-Owned
United States Corporate Income Tax Summary SECTION 1: AT A GLANCE CliftonLarsonAllen LLP 222 Main Street, PO Box 1347 Racine, WI 53401 262-637-9351 fax 262-637-0734 www.cliftonlarsonallen.com Corporate
Cross Border Tax Issues By Reinhold G. Krahn December 2000 This is a general overview of the subject matter and should not be relied upon as legal advice or opinion. For specific legal advice on the information
THE FLORES LAW FIRM Attorney and Counselor at Law 9901 IH-10 West, Suite 800 San Antonio, TX 78230 TEL. (210) 340-3800 FAX (210) 340-5200 MEXICO TAXATION GUIDE I. RECOGNIZED MEXICAN BUSINESS ENTITIES A.
Worldwide personal tax guide 2013 2014 The Netherlands Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Belastingdienst www.belastingdienst.nl
Tax and Succession Planning for Immigration to the United States Michael J. Legamaro May 2011 1 Concerns Upon Moving to US Minimizing US income tax Minimizing US estate tax Managing State law considerations
ADVANCED MARKETS Estate & Gift Tax Treatment for Non-Citizens It goes without saying that the laws governing the U.S. estate and gift tax system are complex. When you then consider the additional complexities
Estate Planning for the International Client Brenda Jackson-Cooper Doug Andre March 24, 2015 I. Rules and Definitions Agenda II. Estate Planning Case Studies III. Questions 2 Effects of U.S. transfer tax
Purchasing U.S. Real Estate Tax Considerations for the Non-U.S. Investor Updated October 2015 Table of Contents Introduction... 2 Ownership in Personal Name... 2 Buying for Personal Use... 3 Buying for
Choosing the Right Entity for Maximum Tax Benefits for Your Construction Company Timely re-evaluation of choice of entity will enhance the shareholder value of your contractor client By Theran J. Welsh
APPENDIX 14 Incorporating International Tax Laws in Multinational Capital Budgeting Tax laws can vary among countries in many ways, but any type of tax causes an MNC s after-tax cash flows to differ from
International Tax 4 th Annual Southwest Tax Conference Las Vegas, Nevada December 4-5, 2012 Brian Phillip Lau Cindy Hsieh firstname.lastname@example.org email@example.com firstname.lastname@example.org 101 2 nd Street, Suite
NON-RESIDENTS PURCHASING REAL PROPERTY IN THE U.S. A. The Attorneys Role in the Purchase of Real Estate The purchase of real estate in the U.S. without the proper assistance can become a complex transaction.
Business Organization\Tax Structure One of the first decisions a new business owner faces is choosing a structure for the business. Businesses range in size and complexity, from someone who is self-employed
in United States Real Estate It is critical that you educate yourself and consult with an experienced tax professional that specializes in international taxation such as the Esquire Group. The prospect
By Pieter A. Weyts1 October 15, 2014 How to Buy U.S. Real Estate as a Non-U.S. Person Navigating the tax considerations of buying U.S. real estate It happens every day in Miami and throughout the United
Thank you for taking the time to complete the Mackenzie Tax and Estate Planning Questionnaire. The following is your personal Tax and Estate Summary Report. This report has been prepared based on the responses
Immigrating to the USA: effective wealth planning Charles P LeBeau, Attorney, San Diego, California, USA Although considerations will vary widely depending on the circumstances of the specific non-resident
INVESTING IRA AND QUALIFIED RETIREMENT PLAN ASSETS IN REAL ESTATE By: Charles M. Lax, Esq. I. DEFINITIONS A. What is a prohibited transaction? 1. A prohibited transaction is defined in IRC 4975(c)(1) as
Worldwide personal tax guide 2013 2014 China Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible State Administration of Taxation
CORPORATE INCOME TAX IN BALTICS Corporate Income Tax Rates in Baltics Country Standard rate Decreased rate Transfer of loses to next periods Latvia 15% 11% microenterprises Unlimited Lithuania 15% Estonia
1-Hour CE Seminar Gift & Estate Planning for Foreign Nationals OLA 1569 0214 This material was not intended or written to be used, and cannot be used, to avoid penalties imposed under the Internal Revenue
INTERNATIONAL TAX COMPLIANCE FOR GOVERNMENT CONTRACTORS Mark T. Gossart Alison N. Dougherty September 26, 2012 2012 All Rights Reserved 805 King Farm Boulevard Suite 300 Rockville, Maryland 20850 301.231.6200
White Paper Life Insurance Coverage on a Key Employee www.selectportfolio.com Toll Free 800.445.9822 Tel 949.975.7900 Fax 949.900.8181 Securities offered through Securities Equity Group Member FINRA, SIPC,
Worldwide personal tax guide 2013 2014 Canada Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Canada Revenue Agency (CRA)
Wealth Planning Summary of U.S. Income, Estate and Gift Taxation for Non-Resident Aliens Overview The United States ( U.S. ) continues to offer attractive investment options to foreign individuals. While
Delivering U.S. International Tax Advice to U.S. Clients Doing Business Abroad OGLE INTERNATIONAL TAX ADVISORS www.ogleintltax.com OUR INTERNATIONAL TAX PRACTICE INCLUDES BOTH CPAS AND ATTORNEYS WITH BIG
U.S. Tax and Estate Planning Issues for Canadians with U.S. Assets or U.S. Citizenship May 28, 2014 Cheyenne J.H. Reese Christine M. Muckle Legacy Tax + Trust Lawyers Smythe Ratcliffe U.S. Residency Issues
TAX NEWSLETTER Special Release: August 2008 REAL OPPORTUNITY: CANADIANS & U.S. REAL ESTATE The weak U.S. economy, the recent subprime mortgage crisis and the strength of the Canadian dollar relative to
Belgium: Tax treatment of immigrating taxpayers IFA Congres Madrid 30 May 2014 Marc Vandendijk Tax Lawyer VANDENDIJK & PARTNERS Rue Edith Cavellstraat 66 1180 Brussels Tel.: + 32 (0)2.343.33.45 E-MAIL:
DETERMINING THE BUSINESS ENTITY BEST FOR YOUR BUSINESS 2015 Keith J. Kanouse One Boca Place, Suite 324 Atrium 2255 Glades Road Boca Raton, Florida 33431 Telephone: (561) 451-8090 Fax: (561) 451-8089 E-mail:
PERSONAL AND CORPORATE TAXATION J. E. Triay Triay & Triay 28, Irish Town Gibraltar The Basis of Taxation? Income tax is charged on the income of any person (includes a company) which either; Accrues in
THE TAX-FREE SAVINGS ACCOUNT The 2008 federal budget introduced the Tax-Free Savings Account (TFSA) for individuals beginning in 2009. The TFSA allows you to set money aside without paying tax on the income
Worldwide personal tax guide 2013 2014 Brazil Local Information Tax Authority Receita Federal do Brasil (RFB) Website www.receita.fazenda.gov.br Tax Year 1 January to 31 December Tax Return due date: Last
Different Types of Corporations: Advantages/ Disadvantages of Corporations Article published at: http://www.morebusiness.com/getting_started/incorporating/d934832501.brc Anyone who operates a business,
Instructions for Form 8938 (Rev. December 2014) Statement of Specified Foreign Financial Assets Department of the Treasury Internal Revenue Service Section references are to the Internal Revenue Code unless
ESTATE PLANNING FOR U.S. NON-CITIZENS & RESIDENTS This Advisory discusses the estate tax benefits for those individuals who are not citizens of the United States and/or spouses of United States citizens
US and PR Estate Tax considerations for Puerto Rico Residents Born in PR or Who Acquired US Citizenship Solely by Residency in PR (PR Persons) By: Ricardo Muñiz, Esq. T he transfer of assets upon death
Investment Structures for Real Estate Investment Funds kpmg.com Contents Investment Structures for Real Estate Investment Funds 01 Who Are the Investors? 02 In What Assets Will the Fund Invest? 03 Will
- 1 - How Canada Taxes Foreign Income (Summary) Purpose of the book The purpose of writing this book, entitled How Canada Taxes Foreign Income is particularly for the benefit of foreign tax lawyers, accountants,
Form 1120S U.S. Income Tax Return for an S Corporation Do not file this form unless the corporation has filed or is attaching Form 2553 to elect to be an S corporation. Information about Form 1120S and
Worldwide personal tax guide 2013 2014 Germany Local information Tax Authority Website Tax Year Tax Return due date 31 May 2013 Is joint filing possible Are tax return extensions possible 2013 income tax
International Taxation Overview of Key Concepts for Tech Companies SJSU High Tech Tax Institute Academy October 21, 2011 William R. Skinner, Esq. email@example.com Fenwick & West LLP Silicon Valley
Health Care Forensic Analysis Insights Considerations in the Health Care Company Tax Status Conversion from C Corporation to Pass-Through Entity Robert F. Reilly, CPA For a variety of economic and taxation
Application of Treaties to Nonresidents: Taxation of Capital Gains Diane Ring Professor of Tax Law Boston College Law School UN-ITC Workshop on Administration of Tax Treaties and Addressing Base-Eroding
EVERYTHING YOU ALWAYS WANTED TO KNOW ABOUT 1031 EXCHANGE (BUT DIDN T KNOW YOU SHOULD ASK ) Nancy N Grekin McCorriston Miller Mukai MacKinnon 5 Waterfront Plaza, 4 th Floor Honolulu, Hawaii 96813 529-7419
Luxembourg holding companies: competitive and tax-efficient June 2009 Table of contents 1. Introduction...3 2. Standard holding company (SOPARFI)...3 3. Double taxation treaties...3 4. Registration taxes...3
TAXPAYER SERVICE DIVISION FYI For Your Information Apportionment of Income C CORPORATIONS A C Corporation doing business only in Colorado will compute its tax on 100% of the Colorado taxable income. However,
Withholding Tax The Indian Constitution has empowered only the Central Government to levy and collect taxes. Every person whose total income exceeds the maximum exemption limit shall be chargeable to the
Presenting a live 90-minute teleconference with interactive Q&A Tax Challenges for Foreign Investors in U.S. Real Estate Navigating the Legal Considerations of Acquiring, Owning and Disposing of U.S. Real
June 2015 Your U.S. vacation property could be quite taxing by Jamie Golombek It seems everywhere we look, Canadians are snapping up U.S. vacation properties. Though your vacation property may be located
KPMG INTERNATIONAL Taxation of Cross-Border Mergers and Acquisitions Panama kpmg.com 2 Panama: Taxation of Cross-Border Mergers and Acquisitions Panama Introduction The signing of several Free Trade Agreements
Taxation The combination of Malta s tax system and its extensive double tax treaty network (over 50) means that, with proper planning and structuring, investors can achieve considerable fiscal efficiency
TAX IMPLICATIONS OF INVESTING IN THE UNITED STATES > RBC DOMINION SECURITIES INC. FINANCIAL PLANNING PUBLICATIONS At RBC Dominion Securities Inc., we have been helping clients achieve their financial goals
Holding companies in Irel David Lawless Paul Moloney Dillon Eustace, Dublin Irel has long been a destination of choice for holding companies because of its low corporation tax rate of 12.5 percent, participation
DESCRIPTION OF THE PLAN PURPOSE 1. What is the purpose of the Plan? The purpose of the Plan is to provide eligible record owners of common stock of the Company with a simple and convenient means of investing
U.S. Tax and Estate Planning Issues May 2014 Cheyenne J.H. Reese Legacy Tax + Trust Lawyers For CFA Vancouver Copyright 2014 Do not reproduce without permission of the author U.S. Residency Issues A Non-U.S.
MARUHAN Co., Ltd. Brief Report on Closing of (connection) for the Term Ended March 31, 2007 (Amounts less than 1 million yen omitted) 1.Business Results for the term ended on March, 2007 (From April 1,
AFGHANISTAN INCOME TAX LAW 2009 An unofficial translation of the Income Tax Law 2009 as published in Official Gazette number 976 dated 18 th March 2009. This translation has been prepared by the Afghanistan
Contents Indian Accounting Standard (Ind AS) 7 Statement of Cash Flows Paragraphs OBJECTIVE SCOPE 1 3 BENEFITS OF CASH FLOW INFORMATION 4 5 DEFINITIONS 6 9 Cash and cash equivalents 7 9 PRESENTATION OF
TOPICS IN THE SEMINAR INCLUDE: The I.R.S. Amnesty Program & The New Streamlined Filing Compliance Procedures By Richard S. Lehman, Esq. TAX ATTORNEY www.lehmantaxlaw.com SEMINAR INTRODUCTION by Richard
TAXATION The following summary of material Cyprus, US federal income and United Kingdom tax consequences of ownership of the GDRs is based upon laws, regulations, decrees, rulings, income tax conventions
` EB-5 Immigrant Investor Program The article documents the U.S. tax implications for foreign nationals participating in the EB-5 Immigrant Investor Program. EB-5 Program The EB-5 Immigrant Investor Program
Basic Tax Issues in Choosing a Business Entity 2015 By Robert M. Finkel and Diana C. Española mbbp.com Corporate IP Licensing & Strategic Alliances Employment & Immigration Taxation Litigation 781-622-5930
Introduction Monaco is a sovereign principality. France is a guarantor of the sovereignty and territorial integrity of Monaco, while Monaco is to conform to French interests. Although the Prince is the