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June 30, 2016 - Haoshen Zhong

Lookthrough Rules for Mutual Funds Held in Foreign Pensions Meeting US Qualifications

Greetings from Haoshen Zhong.

You are receiving this email because you are subscribed to our PFICs Only newsletter, delivered to your inbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom and click “unsubscribe”. To browse our other newsletters, go to hodgen.com/newsletters.

Do I have to report PFICs held in an employer matching pension?

This week’s newsletter is a question we get frequently:

I have a US citizen client who is living and working in Hong Kong. The employer provides a retirement plan where the employee contributes, and the employer matches some percent of the employee contributions.

... continue reading
PFIC and CFCs
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 13, 2016 - Haoshen Zhong

Lookthrough rules for mutual funds held in nonqualified foreign pensions

Greetings from Haoshen Zhong.

You are receiving this email because you are subscribed to our PFICs Only newsletter, delivered to your inbox every other Thursday at 6:00 am Pacific time. To stop receiving these emails, scroll to the bottom and click “unsubscribe”. To browse our other newsletters, go to hodgen.com/newsletters.

Do I have to report PFICs held in an employer matching pension?

This week’s newsletter is a question we get frequently:

I have a US citizen client who is living and working in Hong Kong. The employer provides a retirement plan where the employee contributes, and the employer matches some percent of the employee contributions.

... continue reading
PFIC and CFCs
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

Random
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 Nonresidents with US Activities US Real Estate Investments