Author   /   Phil Hodgen

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.


... continue reading

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.
... continue reading
Friday Edition
June 7, 2016 - Phil Hodgen

A Quick Overview of the Exit Tax

Hi, it’s Phil. I’m going to change up the Expatriation Newsletter for a while. It’s time to write up everything I know about the exit tax. Over the next few months I will be publishing the chapters on a regular schedule.

You can find the updated Chapter 1: A Quick Overview of the Exit Tax here.


 ... continue reading

May 27, 2016 - Phil Hodgen

Double-Dog Dare DAO Token Taxation Discussion (DDDDTTD)

Hey everyone, welcome again to the Friday Edition from Phil Hodgen. You subscribed to this, but you can easily stop it from coming. Just click the “unsubscribe” link at the bottom of this email. We have four other newsletters, too. Go to to sign up if you want more international tax stuff in your life.

This episode is different. It is the Double-Dog Dare DAO Token Tax Discussion. DDDDTTD.1

After a dare – a double-dog dare – to do so from Edmund at, I took a look at the tax treatment of DAO tokens. Hey, Edmund.... continue reading

Friday Edition