FIRPTA Structure Series #7: Use a Nongrantor Trust for Estate Tax Protection
This is the seventh episode of the real estate holding structure series. In this series I walk you through the thought process…
if you want excellence you have to focus on excellence
A variation on the theme, again word for word from @visakanv. (I have a Twitter list with just one person in it:…
FIRPTA Structure Series #6: Add a Foreign Corporation, Achieve Estate Tax Protection
This is the sixth episode of the real estate holding structure series. In this series I walk you through the thought process…
FIRPTA Structure Series #5: Estate Tax Protection With Multi-Entity Holding Structures
The series so far Estate tax protection using single-entity holding structures The series started with a discussion of single-entity holding structures. I…
FIRPTA Structure Series #4: Single-Tier Structures That Prevent Estate TAx
The “Real Estate Holding Structure” Series This is the fourth episode of the real estate holding structure series. In this series I…
When is a foreign corporation a domestic corporation?
Summary Answer: when you run afoul of IRC §7874. IRC §7874 was designed to stop you from reincorporating your U.S. publicly-traded multinational…
FIRPTA Structure Series #3: Avoid Structures With Uncertain Estate Tax Risk
The “Real Estate Holding Structure” Series This is the third episode of the real estate holding structure series. In this series I…
FIRPTA Structure Series #2: Estate Tax is Inevitable With These Structures
Welcome to The Friday Edition. Phil here, in the Bright and Shiny Year of Our Lord 2024. We continue in the series…
FIRPTA Structure Series #1: Introduction, Single Tier Structures, and Impossibility
FIRPTA Holding Structures, Episode 1. Thirteen simple structures exist; three can be quickly eliminated.
Subpart F Income in a Multi-Level Structure, Episode 3
Hello again, welcome to another episode of the Form 5471 show. I am your host, Phil Hodgen. This is Episode 3 of…