Presentation and Q&A: Global Real Estate Transactions

What: Global Real Estate Transactions — Presentation followed by Q&A Time: Tuesday, January 14, 2014 from 1:00 PM to 2:00 PM Where: Malibu Public Library — 23519 Civic Center Way, Malibu, CA  90265 Host: Malibu Association of Realtors – Global Committee Phil will be part of a presentation and Q&A session along with Mitch Creekmore, […]


“Simplicity is hard work. But, there’s a huge payoff. The person who has a genuinely simpler system – a system made out of genuinely simple parts, is going to be able to affect the greatest change with the least work. He’s going to kick your ass. He’s gonna spend more time simplifying things up front […]

East West Bank comments on IRS requirement for nonresident interest reporting

The IRS wants all U.S. banks to report the amount of interest earned on bank deposits owned by nonresident aliens. This last came up 10 years ago, and was resoundingly shot down for obvious reasons. Leadership at the IRS has revived the idea. Cue the obligatory George Santayana reference. Today I saw in Tax Notes […]

Estate tax sunset in 2010 applies to nonresidents

I received an email inquiry from a CPA friend about this, so I thought I would share it generally. Question Does the 2010 repeal of the estate tax apply to nonresidents of the United States? Answer Yes.  The repeal applies to residents and nonresidents alike. Background The estate tax disappeared on December 31, 2009.  It […]

Russian partner in U.S. partnership pays no U.S. income tax

Here is a recent Private Letter Ruling which parses the combined effect of U.S. tax law and the current income treaty between the United States and Russia. A person in Russia is a partner in a U.S. partnership. It looks like a service partnership (accounting firm, law firm, etc.). The person did his/her work in […]

FIRPTA withholding credit given even when the IRS didn’t get the money

In emailed advice released today on Tax Notes Today (2010 TNT 137-56 for you TNT fans) the IRS issued a rare written piece of information on FIRPTA withholding. FIRPTA withholding When a nonresident sells U.S. real estate, Uncle Sam wants to be sure to collect tax on the capital gain that the nonresident makes. This […]

Overview from KPMG for inbound (to the US) business investment

Investment in the United States – A Guide for Foreign Companies [PDF] from KPMG/Canada.  If you need a satellite view of what it takes to expand your business to the United States, this is a decent start. I’m writing an article for Business Law News on the topic.  Will be delivered to the editors today. […]

Outlook for commercial real estate investment

For our clients outside the United States who plan to buy commercial real estate (and I met with some of you on my recent trip to Singapore and Jakarta): By the end of 2010, about half of all commercial real estate mortgages will be underwater, said Elizabeth Warren, chairperson of the TARP Congressional Oversight Panel, […]

Bravo House Ways & Means Committee for RSS

I was trolling through the House Ways & Means Committee website looking for hints of the existence of H.R. 4539, a new bill which significantly alters the taxation of nonresident investors in U.S. real estate. To my utter shock, I found that our trusted servants have enabled RSS for Committee activity. Bravo! (If anyone else […]

IRS interim guidance for dealing with foreign tax officials

This post is about “outbound” disclosure of information. When will the IRS report back to your home country about your financial activities in the United States? One of the long term trends in tax administration will be that there will be increased government-to-government information sharing. That country over there (wherever that is) will feel increasingly […]