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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Personal Holding Company Tax Exposure in Corporate Structures

by Phil Hodgen / 24.05.2024

Basis Step Up for Foreign Assets – How and Why It Works This newsletter is about stepped-up basis for foreign assets inherited by a U.S. taxpayer from a deceased non-U.S. person. Foreign asset, foreign owner who dies, the U.S. tax system never touches the

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Basis Step Up for Foreign Assets – How and Why It Works

by Phil Hodgen / 13.05.2024

Reader’s Question about CFC Strategies This week is a quick break from the FIRPTA content, to answer a reader question about CFCs. An American living abroad owns 100% of a CFC. Here is the question. All the information I find is about deferral but

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Strategies to Deal with CFCs with Lifestyle-level Net Profit

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?