International Tax Law Blog
by Phil Hodgen / 30.08.2024
This week I am writing about how rental income is taxed for nonresident investors in U.S. real estate, and when using a foreign corporation as owner of rental real estate we run into the branch profits tax. Scenario Assume that a foreign corporation owns
by Phil Hodgen / 16.08.2024
Today, you get to look over my shoulder to see how I think through “do I have a grantor trust with a foreign grantor?” Why grantor trusts with foreign grantors are cool The Code doesn’t like it when a foreign person is the grantor
by Phil Hodgen / 06.08.2024
The Punchline If you want to skip the appetizers and go straight to dessert: Consider a U.S. corporation doing business abroad. If it conducts its business through a foreign disregarded entity, the income is taxed on Form 1120 at 21%. If it conducts its
by Phil Hodgen / 05.07.2024
The Punchline Form 5471 is required for an individual who is a resident alien and claims U.S. nonresident status because of an income tax treaty. This is true even though subpart F income and global intangible low-taxed income reported by way of that Form
by Phil Hodgen / 21.06.2024
This discussion is inspired by a question I got from Marissa M., so thank you for that. 🙂 Her question was not what I discuss here, but it reminded me of a problem that pops up again and again. Summary Here’s what happens. A
by Phil Hodgen / 07.06.2024
This week’s newsletter The May 31, 2024 International Tax Lunch webcast covered foreign investors in U.S. real estate and specifically the use of corporate structures to hold the real estate assets. Joshua Maya, a frequent correspondent, asked a question about personal holding company tax
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