How I Analyze a Foreign Trust for Grantor Trust Status
Today, you get to look over my shoulder to see how I think through “do I have a grantor trust with a…
Why the Disregarded Entity Election is Not Necessarily a Good Idea
The Punchline If you want to skip the appetizers and go straight to dessert: Consider a U.S. corporation doing business abroad. Why…
Why Treaty Nonresidents Must File Form 5471
The Punchline Form 5471 is required for an individual who is a resident alien and claims U.S. nonresident status because of an…
Buying Real Estate Before Setting Up a Holding Structure
This discussion is inspired by a question I got from Marissa M., so thank you for that. 🙂 Her question was not…
Personal Holding Company Tax Exposure in Corporate Structures
This week’s newsletter The May 31, 2024 International Tax Lunch webcast covered foreign investors in U.S. real estate and specifically the use…
Basis Step Up for Foreign Assets – How and Why It Works
Basis Step Up for Foreign Assets – How and Why It Works This newsletter is about stepped-up basis for foreign assets inherited…
Strategies to Deal with CFCs with Lifestyle-level Net Profit
Reader’s Question about CFC Strategies This week is a quick break from the FIRPTA content, to answer a reader question about CFCs….
FIRPTA Structure Series #9: Can a Corporation Take a Property Tax Deduction for Personal-Use Real Estate?
This week’s article is a request for you to email me and say “Oh, you’re so wrong Phil.” “So, so wrong.” (Walks…
FIRPTA Structure Series #8: Corporate Structures and Imputed Income Problems
This is another episode in the FIRPTA Series. We are looking at the tax complications – and there are many – for…
When is a Portfolio Interest Loan Useful?
This is just a little interlude about portfolio interest for nonresident real estate investors. I just got through working on a portfolio…