Inbound U.S. investments


Real estate holding structures for nonresidents – tax law changes coming

This is a distant early warning to nonresidents with U.S. real estate investments. The warning applies to multi-national corporations as well (businesses that operate in the United States and elsewhere in the world) but I am going to focus on real estate investors here. RISK An proposed change in U.S. tax law may double the […]

Sign of the times

Got off the phone with an unnamed Swiss gentleman who is in the banking and trust company business. Flat out refuses to touch any business involving a U.S. citizen. Reports he gets several calls a week about this. Current political and tax trends in the United States can only be described as isolationist and protectionist […]

The “net election” for nonresident landlords

This is for the members of my Foreign Investment in U.S. Real Estate Class earlier this week in San Francisco. We talked about the “net election.” Here’s the detail I promised. The law To learn everything about this, read Treasury Regulations Section 1.871-10. (PDF). The effect Rental income earned by a nonresident owner of U.S. […]

Doing business in California

This one is for the people who were in my Foreign Investment in U.S. Real Estate class yesterday in San Francisco. In re B & G Properties, Inc. (PDF) is an opinion from the State Board of Equalization that helps you answer the question “Does this foreign corporation register with the Secretary of State?” The […]

New foreign bank account reporting form

The IRS has a new version of Form TD F 90-22.1. You have to use it for all filings after December 31, 2008. More (including editorializing) later, but for the moment here is the link to the form on the IRS website. http://www.irs.gov/pub/irs-pdf/f90221.pdf Sorry the link isn’t prettier but WordPress is acting funny. Couldn’t be […]

Mentioned in the Hi-Desert Post

I spoke in Palm Springs a couple of weeks ago to an enthusiastic and large group of Realtors about representing foreign buyers and sellers of real estate. (There is a pretty large snowbird contingent in the Coachella Valley). Louis Perlin of Marilyn Perlin Realtors, Inc. in Palm Springs was kind enough to introduce himself after […]