1 Avoiding U.S. Investment Tax Traps Structuring Real Estate and Other Fund Investments Presented by: Joseph Gulant and Daniel Blickman
2 Major Categories of Tax to Consider in Planning International Transactions Step 1: Cash investment in stock or debt Transaction Tax, if any Foreign Corp. (Cayman Islands) Step 3: Foreign country corporate tax Repatriation Tax Dividends or interest; U.S. Withholding Tax Repatriation Tax U.S. Corp. Operating income Step 2: U.S. corporate income tax Operational Tax
3 Major Categories of Tax to Consider in Planning International Transaction (con t.) Exit Tax in U.S., if any, and/or Foreign Country Foreign Corp. Step 4: Stock of U.S. Corp. Cash Buyer U.S. Corp.
4 I. Portfolio Investing (FDAP; Non-ECI) Foreign Corp. Foreign Corp. Cash investment in stock or debt Dividends or interest Contract Rent, royalties, payments for services, etc. U.S. Corp. U.S. Corp. The technical term for portfolio income is fixed or determinable annual or periodical income, profit, or gains (FDAP).
5 II. Trade/Business Investing (ECI) Foreign Corp. Foreign Corp. Foreign Corp. U.S. Branch (U.S. T/B) U.S. Partnership (U.S. T/B or U.S. Real Estate) U.S. Real Estate The technical term for income effectively connected with a U.S. trade or business is ECI (effectively connected income).
6 Portfolio Investing Tax Reporting Foreign Corp. Foreign Country corporate income tax Provides Form W-8 Equity or debt Dividends or interest, net of WH Tax; and Form 1042-S U.S. Corp. WH Tax and Forms 1042 and 1042-S IRS Operating income U.S. Corporate income tax
7 Portfolio Investing Tax Reporting (con t) Foreign Corp. Stock of U.S. Corp. Cash Buyer U.S. Corp. Generally no Exit Tax in U.S. on capital gains.
8 Trade/Business Investing Tax Reporting IRS Foreign Corp. files U.S. tax return and pays U.S. branch profits tax Dividend equivalent Foreign Corp. No foreign tax? Foreign Gov t No foreign tax? Foreign Corp. Distributions of dividend equivalent Foreign Corp. files U.S. tax return and pays U.S. corporate income tax and branch profits tax IRS IRS Foreign Corp. files U.S. tax return and pays U.S. corporate income tax U.S. Branch or U.S. Real Estate (U.S. T/B) Operating Income Partnership Partnership Withholding U.S. T/B IRS Operating Income
9 Trade/Business Investing Tax Reporting (con t) IRS Foreign Corp. files U.S. tax return and pays U.S. corporate income tax on gain Foreign Corp. U.S. Branch Assets/ U.S. Real Estate/ U.S. Partnership Interest Cash Buyer U.S. Branch U.S. Real Estate Partnership U.S. T/B Gain on sale of the U.S. T/B will not be subject to the Branch Profits Tax if Foreign Corporation terminates its U.S. T/B activities in year of sale
10 Joint Venture U.S. Blocker Corporation Structure Foreign Corp. Use of U.S. blocker corporation turns ECI into FDAP at the border with respect to foreign corporation. WH Tax responsibility falls on U.S. blocker corporation, not on U.S. partnership. U.S. Blocker Corp. Operating income U.S. Partnership with U.S. Branch or U.S. Real Estate U.S. Partner
11 Foreign Investor in U.S. Fund A Typical Structure Foreign Corp. U.S. Investors Share of dividends or interest from U.S. Portfolio Corporation is FDAP to Foreign Corporation. U.S. blocker corporation required to turn ECI into FDAP with respect to Foreign Partnership for Fund s investment in U.S. Portfolio Partnership. U.S. Portfolio Corporation U.S. T/B (other than primarily holding real estate) U.S. Fund U.S. T/B U.S. Blocker Corp. U.S. Portfolio Partnership
12 Typical Structure for Offshore Fund Investing in U.S. Portfolio Companies Cayman Islands Fund must invest in U.S. Portfolio Partnership through U.S. blocker corporation to avoid ECI from this investment; Investment in U.S. Portfolio Corporation is FDAP. Foreign Corp. U.S. Portfolio Corporation Cayman Islands Fund Other Investors (e.g., U.S. tax exempts) U.S. Blocker Corp. U.S. Portfolio Partnership
13 Lending Funds Foreign Corp. Cayman Islands Fund Loans purchased on secondary market Not engaged in a U.S. T/B FDAP income Generally no WH Tax under Portfolio Interest exemption Loans originated by Fund May be U.S. T/B If U.S. T/B, income is ECI Fund subject to U.S. corporate net income tax and branch profits tax
14 Varieties of IRS Form W-8 Form W-8BEN Form W-8IMY Foreign Individual No Form W-8 Foreign Corp or Foreign Individual U.S. Partner Foreign Corp. Form W-8BEN Form W-8ECI Swiss Bank Corporation U.S. Withholding Agent Foreign Individual Form W-8BEN Form W-8BEN Foreign Partnership U.S. Withholding Agent Form W-9 Form W-8IMY, accompanied by Form W-8BENs and Form W-9s from partners Form W-8ECI U.S. Branch U.S. Withholding Agent (Borrower)
15 Tax Planning For Investments In U.S. Basic Considerations U.S. Estate and Gift Tax U.S. and Foreign Income Tax Considerations Income Tax Filing Obligations
16 Tax Planning For Investments In U.S. Planning for the U.S. Estate/Gift Tax Form of Inheritance Taxes Separate and Apart from Income Taxes General Rule: U.S. situs property held by U.S. nonresident alien at time of death is subject to U.S. estate tax Rates currently up to 45% (subject to legislative change) Results may also be changed by Tax Treaties What types of property are subject to U.S. estate tax? U.S. real property Stock in U.S. corporations and debt obligations issued by U.S. corporations Interests in U.S. investment funds (partnerships) if partnership holds U.S. property Other Nonqualified deposits Partnership Interests?
17 Tax Planning For Investments In U.S. Planning for the U.S. Estate Tax What types of property are not subject to U.S. estate tax? Stock in foreign corporations Most deposits in U.S. financial institutions Deposits in Non-U.S. financial institutions Debt Instruments of U.S. persons eligible for portfolio interest exemptions Other
18 Estate/Gift Tax Planning For Investments In U.S. Treatment of Partnership Interests For U.S. Estate Tax Purposes Treatment unclear Intangible Asset Aggregation or Separate? IRS position (Revenue Ruling ): situs for estate tax purposes is where partnership is doing business Risk of Estate Taxation Transfers of Intangible Property generally not subject to U.S. Gift Tax IRS will not rule on taxability of transfers of partnership interests by Nonresident Aliens for Gift Tax purposes Transfers of Partnership Interests prior to death may avoid U.S. Estate and Gift tax TAX TRAP: Transfers of Partnership Interests with Liabilities in Excess of Tax Basis
19 U.S. Estate/Gift Tax Considerations (cont.) How to minimize risk of U.S. Estate/Gift Taxation? Invest in U.S. through non-u.s. blocker corporation Ownership interest in foreign corporation is not U.S. property for U.S. Estate and Gift tax purposes
20 Basic Income Tax Considerations Nonresident Aliens generally subject to income tax on two types of income: Fixed or Determinable Annual or Periodic Income ( FDAP ) Types (wages, interest, dividend, rents, royalties, etc.); Must be derived from U.S. sources; and Generally subject to withholding (by paying agent) at 30% (subject to reduction under tax treaties). Withholding on Gross Income Income Effectively Connected with a U.S. Trade or Business ( ECI )
21 U.S. Effectively Connected Income What is U.S. ECI? Whether a taxpayer is engaged in a U.S. trade or business is based on facts and circumstances Activities must generally be regular and continuous Key Distinction: business activities of a partnership will be attributed to the partners Tax return filing obligations and income tax withholding by U.S. partnerships
22 U.S. Effectively Connected Income What is U.S. ECI? Treaty protections if no permanent establishment in U.S., but special rules apply to real estate (generally allowed to be taxed under most tax treaties) Key Distinction: Income and Gains from sales of stock and securities for own account or sales through brokers or commission agents are not treated as ECI under Section 864 of the Code Includes income from Investment Partnerships
23 Capital Gain Income Treatment of Capital Gains Under U.S. income tax law, capital gains from U.S. investments are generally not subject to U.S. income tax or withholding tax unless: recipient is in U.S. for 183 days or more in taxable year in which earned Key Distinction: Under the Foreign Investment In United States Real Property Tax Act ( FIRPTA ), capital gains from the sale of U.S. real property will automatically be treated as U.S. ECI and will be taxable in the U.S.
24 Special Considerations Investment In U.S. Real Estate Rents earned by U.S. nonresident alien may be subject to 30% withholding tax on Gross Income No deductions for operating expenses, depreciation, interest expense, etc. If arrangement is U.S. ECI, then nonresident alien taxed on net income Section 871(d): Special election to treat real estate rental income as ECI
25 Special Considerations Investment In U.S. Real Estate If made, Section 871(d) election will allow Nonresident alien to be taxed on net basis Nonresident alien will need to file income tax returns in the U.S. (Form 1040-NR) in order to be taxed on a net basis and satisfy other requirements (e.g., W-8 ECI) As capital gains from sale will generally be subject to FIRPTA tax in U.S. in any event, Section 871(d) election will not impact status of property gains as taxable in the U.S.
26 What types of property are subject to FIRPTA? United States Real Property Interests Includes: Direct ownership interests in real property Interests in U.S. Corporations where more than 50% of assets are U.S. real property interests Interests in U.S. partnerships (to the extent that assets are made up of U.S. real property interests) Interest in U.S. Real Estate unless solely in status as a creditor Debt obligation of U.S. borrower with equity kicker will likely be treated as U.S. Real Property Interest
27 What types of property are not subject to FIRPTA? United States Real Property Interests do not include: Interests in domestically controlled REIT < 50% foreign ownership Ownership interests in certain U.S. corporations 5 Year Rule on Complete Dispositions < 5% ownership interests in publicly traded corporations Ownership Interests in Foreign Corporations Planning to avoid FIRPTA Insurance Wrapped Investments
28 U.S. Effectively Connected Income What if a Foreign Corporation has U.S. ECI? Foreign corporation will be subject to tax on a net basis Taxed at rates up to 35% Foreign corporation will also be subject to second level of income tax (the so-called Branch Profits Tax )
29 U.S. Effectively Connected Income What if a Foreign Corporation has U.S. ECI? Branch Profits Tax is generally imposed on net profits not reinvested in the U.S. trade or business, regardless of whether distributed, at a 30% tax rate (subject to treaty reduction) Branch Profits Tax generally equates to withholding tax on dividends if foreign corporation were operating through a U.S. subsidiary Avoidance of Branch Profits Tax on Sale Complete Dispositions of U.S. Real Property Interests
30 U.S. Income Tax Filing Considerations If U.S. Sourced FDAP income or U.S. ECI, then income tax filing obligations in United States (Form 1040-NR and other forms to claim Treaty benefits, if applicable) Individuals must obtain U.S. taxpayer identification numbers to file returns Loss of anonymity May be non-starter for many non-u.s. tax residents
31 U.S. Income Tax Filing Considerations How to eliminate U.S. income tax filing obligations? Use Foreign Corporations as blocker corporations to hold U.S. investments Blockers usually formed in low or no tax jurisdictions (Cayman Islands, Bermuda, British Virgin Islands, etc.)
32 U.S. Income Tax Filing Considerations (cont.) Filing obligations for income taxes, if applicable, may include state and local income tax returns
33 Advantages/Disadvantages of Advantages: Blocker Corporations Retain anonymity Eliminate U.S. Estate/Gift Tax Issues Always should review situation in home jurisdictions Disadvantages: Income Tax Inefficiencies Direct ownership would generally be the most tax-efficient approach (one level of tax, capital gain rates preservation) Corporate ownership generally creates two levels of tax, subject to special tax planning strategies
34 Structures for Minimizing Income Tax Inefficiencies of Blocker Corp. Cash investment in stock and debt (60/40 Debt/Equity Ratio) Foreign Corp. (No local tax on dividend distributions repatriated to Foreign Corp.) Dividends or interest; U.S. Withholding Tax Repatriation Tax U.S. Corp. Operating income -No withholding tax on principal payments U.S. corporate income tax Operational Tax (reduced by interest expense)
35 Portfolio Interest Exception 0% WH Tax Form W-8 Debt in registered form Foreign Corp. Portfolio Interest U.S. Corporation 0% WH Tax on Portfolio Interest. Portfolio Interest: registered form debt instrument; interest must not be contingent; must receive Form W-8; does not apply to: 10% owners; interest paid to banks in the ordinary course; or interest paid to CFCs by a related person
36 Inbound Investments in U.S. Real Estate Foreign Corp. A Foreign Corp. B U.S. Blocker Corp. 1 U.S. Real Estate Venture 1 U.S. Blocker Corp. 2 U.S. Real Estate Venture 2 U.S. Blocker Corp. 3 U.S. Real Estate Venture 3 U.S. Sub 1 U.S. Real Estate Venture 1 U.S. Holding Corp. U.S. Sub 2 U.S. Real Estate Venture 2 U.S. Sub 3 U.S. Real Estate Venture 3
37 Inbound Investments in U.S. Real Estate (con t) No U.S. Holding Corp. Con: Profits and losses on separate ventures cannot offset each other to reduce U.S. Operational Tax Pro: As each venture is sold, each U.S. Blocker Corp. can liquidate without U.S. WH Tax (no Repatriation Tax in U.S.) More likely to be used if ventures expected to be repatriated at different times U.S. Holding Corp. Pro: Profits and losses on separate ventures can offset each other within U.S. consolidated tax return Con: As each venture is sold, repatriation of proceeds may be subject to U.S. WH Tax More likely to be used for portfolio of assets with longer expected holding periods
38 Tax Treaties Anti-Abuse Rules on Treaty Shopping Less Favorable or No Treaty Benefit, if transaction done directly between Country A and U.S. (15% WH Tax) Foreign Corp. (Country A) Foreign Corp. (Country B) Favorable Treaty Provision (0% WH Tax) Intermediary Corporation Inserted for Treaty Provisions Favorable Treaty Provision (0% WH Tax) U.S. Corporation Anti-abuse rules in U.S. Tax Treaties generally prevent treaty shopping. Code and Treasury Regulations contain more anti-abuse rules (Section 884(f); Treasury Regulations Section anti-conduit regulations; Section 894).
39 Interest Stripping Rules Code Section 163(j) Foreign Corporation $1 MM interest $2 MM equity $8 MM 12.5% Taxable Income $1,000,000 (pre-interest) Interest paid $1,000,000 Interest Deduction (500,000) Net Taxable Income $ 500,000 U.S. Corporation Operating Income $1 MM U.S. Corporation earns $1 MM of taxable income (before interest expense) for the taxable year. U.S. Corporation pays $1 MM of interest to Foreign Corporation (i.e., $8 MM x 12.5% = $1 MM). Code Section 163(j) limits interest deduction for U.S. Corporation to $500K. Formulation of rules generally allows financial institutions not to be affected insofar as rules are directed at interest expense net of interest income and financial institutions have large amounts of interest income.
40 Summary Taxes at Issue Transaction, Operational, Repatriation, Exit Goals Avoid double taxation Tax deferral Reduce overall tax liability Withholding Tax Responsibility Tax filings and information reporting Practicalities Clients generally want to achieve these goals with simplest possible structures substantial tax savings needed for toleration of tax planning extras Need to work with foreign tax and corporate counsel to co-ordinate tax rules in each country Very complicated area of the law, but general uniformity in basic concepts almost everywhere
41 To learn more Daniel R. Blickman Business Tax, Philadelphia Joseph T. Gulant Business Tax, Philadelphia & New York
Estate Planning and Income Tax Issues for Nonresident Aliens Owning US Real Estate 1. Introductory Matters. Presented by Paul McCawley Greenberg Traurig, P.A. firstname.lastname@example.org 954.768.8269 October 24,
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
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
Select US Real Estate Investment Structures for Foreign Investors 10. February 2012 Francis J. Helverson, WTS USA email@example.com CIRCULAR 230 DISCLOSURE Pursuant to Regulations governing practice
Tax Guide for 2015 TAX ASPECTS OF MUTUAL FUND INVESTING INTRODUCTION I. Mutual Fund Distributions A. Distributions From All Mutual Funds 1. Net Investment Income and Short-Term Capital Gain Distributions
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
UNDERSTANDING U.S. TAXATION OF FOREIGN INVESTMENT IN REAL PROPERTY Steven Hadjilogiou, Baker & McKenzie LLP, Miami Michael Melrose, Baker & McKenzie LLP, Miami OVERVIEW OF TOPICS Taxation of Income from
Originally published in: The Canadian Tax Journal August, 2013 Options to Consider for Non-US Investors in US Real Estate By: Michael J. Miller INTRODUCTION Foreign individuals investing in US real estate
Planning for Foreign Persons Investing in U.S. Real Estate 2014 ABA Annual Meeting August 10, 2014 Michael Hirschfeld Philip R. Hirschfeld Mark Stone Dechert LLP Ruchelman P.L.L.C. Holland & Knight LLP
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
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
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,
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
2 ND BIENNIAL ONTARIO NEW YORK LEGAL SUMMIT STRUCTURING FOR COMMERCIAL AND PERSONAL INVESTMENTS Co-Chairs: Thomas Nelson, Hodgson Russ LLP Lorne Saltman, Gardiner Roberts LLP Panelists: Mary Voce, Greenberg
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
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
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
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
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
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
International Issues Affecting Domestic Planners Robert D. Colvin (Houston, Texas, USA) Houston Business & Estate Planning Council October 22, 2009 Overview of Presentation Offshore Voluntary Disclosure
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
TAX CONSIDERATIONS IN REAL ESTATE TRANSACTIONS Investment by Foreign Persons in U.S. Real Estate Keith R. Gercken Pillsbury Winthrop LLP San Francisco, California Overview U.S. taxation of foreign persons
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
digitalcommons.nyls.edu Faculty Scholarship Articles & Chapters 1-30-2012 Tax Structuring of Foreign Investment in U.S. Real Estate with a N.Y. Twist Alan Appel New York Law School Jack Mandel Bryan Cave
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
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
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
April 2012 CONTENTS U.S. basis of taxation The benefits of the Canada-U.S. tax treaty U.S. filing requirements U.S. taxpayer identification U.S. withholding Tax U.S. state taxation Other considerations
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
Page 1 of 9 UPDATE ON NON-RESIDENT INVESTMENT IN CANADIAN REAL ESTATE Jack Bernstein Aird & Berlis LLP Toronto, Canada To be submitted for publication in Tax Notes International, 2015 The stable Canadian
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
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
H.R. XXX Small Business Tax Relief Act of 2010 July 30, 2010 I. SMALL BUSINESS TAX RELIEF Provide small business tax relief by repealing certain information reporting requirements to corporations and to
TECHNICAL EXPLANATION OF THE REVENUE PROVISIONS OF H.R. 5901, THE REAL ESTATE JOBS AND INVESTMENT ACT OF 2010 Prepared by the Staff of the JOINT COMMITTEE ON TAXATION July 29, 2010 JCX-41-10 CONTENTS INTRODUCTION...
EFFECTIVE INTERNATIONAL INTELLECTUAL PROPERTY STRATEGIES TO MITIGATE U.S. TAXES DENNIS S. FERNANDEZ INNA S. SHESTUL Fernandez & Associates, L.L.P. Fernandez & Associates, L.L.P. 1047 El Camino Real, Ste
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
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.
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
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.
TAX PLANNING FOR CANADIANS PURCHASING PROPERTY IN FLORIDA By: Michael J. Wilson and Heather A. Cooper Canadians have long been active in Florida real estate. Whether owning a vacation home or an investment
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
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
TAX PLANNING FOR FOREIGNERS PURCHASING PROPERTY IN FLORIDA January 15, 2015 By Michael J. Wilson Shareholder, Board Certified Tax Attorney Foreigners have long been active in Florida real estate. Whether
One of the most important decisions facing a new business owner is the selection of the most appropriate legal entity for their new business. There are several options including C Corporations, S Corporations,
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
SPECIAL UPDATE US Inbound Investment Strategies For Renewable Energy by Keith Martin, in Washington A new wave of Chinese, Spanish and some other European and Latin American companies is investing in US
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
OFFSHORE INVESTMENT U.S. INTERNATIONAL TAX PLANNING AN ASIAN PERSPECTIVE June 9th and 10th, 2010 SHANGHAI Harriet Leung firstname.lastname@example.org Brian email@example.com & Company LLP 101 Second Street, Suite
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
REITs and infrastructure projects The next investment frontier? 2 Coming out of the economic downturn, private investors are seeking new avenues to generate tax-efficient returns on their invested funds.
FOREIGN INVESTMENT IN U.S. REAL PROPERTY FROM PURCHASE TO DISPOSITION Miguel G. Farra, CPA, JD Jeffrey Blinn, CPA, JD Erick R. Wendelken, CPA 1001 Brickell Bay Drive, 9 th Floor Miami Florida 33131 Telephone:
Instructions for the Requester of Forms W 8BEN, W 8BEN E, W 8ECI, W 8EXP, and W 8IMY (Rev. July 2014) Section references are to the Internal Revenue Code unless otherwise noted. Future developments. For
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
Form 1120 Department of the Treasury Internal Revenue Service A Check if: 1a Consolidated return (attach Form 851). b Life/nonlife consolidated return... 2 Personal holding co. (attach Sch. PH).. 3 Personal
Offshore Hedge Funds vs. Onshore Hedge Funds A Fund Associates White Paper, December 2008 Offshore Hedge Funds vs. Onshore Hedge Funds I. Who May Invest In Offshore Hedge Funds Investors in offshore hedge
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
Certain Investor Tax Considerations for Investing in U.S. Funds David Sussman August 2014 2014 Duane Morris LLP. All Rights Reserved. Duane Morris is a registered service mark of Duane Morris LLP. Duane
Tax planning for employees coming to work in the U.S. Up close Tax > International tax > Expatriate taxes In U.S. tax law the term alien refers to a foreign national (an individual who is not a citizen
Presentation: International Income Taxation Chapter 3: FOREIGN PERSON S US TRADE OR BUSINESS INCOME Professors Wells January 27, 2014 Chapter 3 Foreign Persons: U.S. Trade or Business Income Fundamental
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:
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
Tax Reform in Brazil and the U.S. Devon M. Bodoh Principal in Charge Latin America Markets, Tax KPMG LLP Carlos Eduardo Toro Director KPMG Brazil Agenda Overview of Global Tax Reform Overview Organization
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
IRS regulations The Foreign Account Tax Compliance Act (FATCA) and its impact on the US foreign withholding tax and reporting system What is FATCA? The Foreign Account Tax Compliance Act (FATCA) is a new
Department of the Treasury Internal Revenue Service Publication 515 Cat. No. 15019L Withholding of Tax on Nonresident Aliens and Foreign Entities For use in 2013 Contents What's New... 1 Reminders... 2
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
Chapter 9 FEDERAL TAXATION OF RESIDENT ALIENS Jennifer A. Mace 1 9.1 INTRODUCTION Planning a foreign national s transfer to the United States requires consideration of a number of tax and non-tax related
TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS LAWS AND DECREES The Income Tax (Amendment) Law of 2005 The Special Contribution for Defence (Amendment) Law of 2004 The Assessment and Collection
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
A Account A record of a business transaction. A contract arrangement, written or unwritten, to purchase and take delivery with payment to be made later as arranged. Accounts payable Money which you owe
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
Corporate Taxation & Structuring in Canada and Canadian Scientific Research & Experimental Development Program Overview (SR&ED) Claude E. Jodoin, M.Fisc. Maximize your R&D $...Look North of the border!
Foreign Persons Investing in U.S. Real Estate: Partnership and Other Structures, Opportunities and Traps NYU Summer Institute in Taxation: Advanced International Tax July 23, 2015 Alan I. Appel Michael
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