Author   /   Phil Hodgen

July 22, 2016 - Phil Hodgen

Former green card holder returning to the United States as a visitor

If you sign up for one of my email newsletters, you will get a bot-response from me, thanking you for signing up.  But if you ask a question, the response is remarkably lifelike, because I actually write the answer.  🙂

Today reader S.J. signed up and here is what he wanted to know.  I have edited his comments slightly for formatting and clarity, but mostly to hide identifying information.

1 – What’s the single most important question you have about international tax?

I abandoned my LPR green card in ______, 2015 (delivered my Green Card with Form I-407 to the US embassy) and was given a visitor visa.

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Nonresidents with US Activities
July 19, 2016 - Phil Hodgen

Closure After Expatriation

Hi again, and thanks for reading. It’s Phil with the every-other-week Expatriation Only email newsletter. You can unsubscribe by clicking the link at the bottom of this email.

Closure After Expatriation

This week is an answer to an email I received from a reader. It asks about what happens after you file that final income tax return.

It is a fairly common question, and there is a short, but unsatisfactory (to those of us who are a teensy bit OCD) answer.

I would like to thank you for the wealth of information you have shared in your expatriation blog. It has certainly helped me greatly in trying to work my way through the entire process.

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June 24, 2016 - Phil Hodgen

Trust Structures for Nonresident Real Estate Investors

Nongrantor trusts offer excellent tax performance for nonresident investors in U.S. real estate:

  • Estate tax risk is eliminated; and
  • Long term capital gains tax treatment applies to capital gains.

But everything has its price. These excellent tax results come at the expense of:

  • Significant set-up costs.
  • Significant operating costs.
  • Loss of control.
  • Capital — and capital gain — no longer belong to the investor.
Shameless Promotion: More on July 8, 2016

This episode of the Friday Edition gives you an overview of the benefits and risks. If you want more detail, you might consider an upcoming webcast/phone presentation on the topic.... continue reading

Friday Edition
June 10, 2016 - Phil Hodgen

My correspondents make me jealous

I traded emails earlier this morning with a tax lawyer friend who happens to be in Istanbul right now.  This is the view from his balcony.  I am deeply jealous.


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June 10, 2016 - Phil Hodgen

Pooled Capital for Real Estate Investments by Nonresidents

Holding Structures for Pooled Nonresident Real Estate Investment

A group of nonresident individuals want to pool their money to buy commercial real estate in the United States.

They are going to buy decent-sized properties — commercial and office properties in the $5 million to $50 million range. This is serious money but not crazy huge.

How should they set this up for optimum U.S. tax results?

The Factors to Consider

The factors to consider are:

  • Estate tax. People die, and when they do, the Internal Revenue Service looks around to see if there are any assets can be taxed. Nonresident individual investors can — and should — eliminate that estate tax risk.
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Friday Edition Nonresidents with US Activities US Real Estate Investments