How To Make Domestic Corporation Stock Not be a USRPI
International Tax Insiders Just dropping it here: if you want to join a group of international tax pros, maybe you’ll want to…
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Deduction or Capitalization of Carrying Costs for U.S. Real Estate
Nonresident Owns a U.S. House The scenario is a common one: a nonresident individual owns a house in the United States. Having…
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Branch Profits Tax for Rental Income
This week I am writing about how rental income is taxed for nonresident investors in U.S. real estate, and when using a…
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Buying Real Estate Before Setting Up a Holding Structure
This discussion is inspired by a question I got from Marissa M., so thank you for that. 🙂 Her question was not…
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Personal Holding Company Tax Exposure in Corporate Structures
This week’s newsletter The May 31, 2024 International Tax Lunch webcast covered foreign investors in U.S. real estate and specifically the use…
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FIRPTA Structure Series #9: Can a Corporation Take a Property Tax Deduction for Personal-Use Real Estate?
This week’s article is a request for you to email me and say “Oh, you’re so wrong Phil.” “So, so wrong.” (Walks…
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FIRPTA Structure Series #8: Corporate Structures and Imputed Income Problems
This is another episode in the FIRPTA Series. We are looking at the tax complications – and there are many – for…
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When is a Portfolio Interest Loan Useful?
This is just a little interlude about portfolio interest for nonresident real estate investors. I just got through working on a portfolio…
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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…
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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…