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…
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…
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…
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…
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…
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…
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…
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…
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…
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…