by Phil Hodgen / 26.04.2024

This week’s article is a request for you to email me and say “Oh, you’re so wrong Phil.” “So, so wrong.” (Walks away, shaking head sadly). Tell me I’m wrong. It’s a question about tax deductions for a C corporation when the shareholder lives

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FIRPTA Structure Series #9: Can a Corporation Take a Property Tax Deduction for Personal-Use Real Estate?

by Phil Hodgen / 12.04.2024

This is another episode in the FIRPTA Series. We are looking at the tax complications – and there are many – for nonresidents who simply buy a house in the United States for personal use. Imputed income from personal use of corporate-owned property This

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FIRPTA Structure Series #8: Corporate Structures and Imputed Income Problems

by Phil Hodgen / 29.03.2024

This is just a little interlude about portfolio interest for nonresident real estate investors. I just got through working on a portfolio interest loan transaction, so this is fresh in my head. Professions are a conspiracy against the laity, said George Bernard Shaw. And

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When is a Portfolio Interest Loan Useful?  

by Phil Hodgen / 29.03.2024

This is the seventh episode of the real estate holding structure series. In this series I walk you through the thought process of a non-resident who wants to buy a home in the United States for personal or family use–not for rental. This episode

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FIRPTA Structure Series #7: Use a Nongrantor Trust for Estate Tax Protection

by Phil Hodgen / 09.03.2024

A variation on the theme, again word for word from @visakanv. (I have a Twitter list with just one person in it: @visakanv). This is of importance to the new venture. I want to attract the best of the best. I will wave the

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if you want excellence you have to focus on excellence

by Phil Hodgen / 01.03.2024

This is the sixth episode of the real estate holding structure series. In this series I walk you through the thought process of a non-resident who wants to buy a home in the United States for personal or family use–not for rental. ​​Episode 1​

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FIRPTA Structure Series #6: Add a Foreign Corporation, Achieve Estate Tax Protection