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

by Phil Hodgen / 16.02.2024

The series so far Estate tax protection using single-entity holding structures The series started with a discussion of single-entity holding structures. I brain-dumped all of the holding structures I could think of, then walked you through the analysis of which structures provided estate tax

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FIRPTA Structure Series #5: Estate Tax Protection With Multi-Entity Holding Structures

by Phil Hodgen / 02.02.2024

The “Real Estate Holding Structure” Series This is the fourth 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

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FIRPTA Structure Series #4: Single-Tier Structures That Prevent Estate TAx

by Phil Hodgen / 25.01.2024

Summary Answer: when you run afoul of IRC §7874. IRC §7874 was designed to stop you from reincorporating your U.S. publicly-traded multinational in, say, Bermuda. But it will apply equally to a nonresident doing normal estate tax planning for very ordinary U.S. real estate.

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When is a foreign corporation a domestic corporation?

by Phil Hodgen / 19.01.2024

The “Real Estate Holding Structure” Series This is the third 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

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FIRPTA Structure Series #3: Avoid Structures With Uncertain Estate Tax Risk

by Phil Hodgen / 05.01.2024

Welcome to The Friday Edition. Phil here, in the Bright and Shiny Year of Our Lord 2024. We continue in the series about holding structures for nonresidents who buy U.S. real estate.  In the last episode . . . In the first episode, I

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FIRPTA Structure Series #2: Estate Tax is Inevitable With These Structures