October 31, 2003 - admin

New IRS regulations for nonresident real estate investors

Here's a link to the IRS website for the new Regulations governing foreign investors in U.S. real estate. It covers withholding, the use of taxpayer identification numbers, how disregarded entities are treated in the withholding context, and even (miracle of miracles) the use of Section 121 by a nonresident alien.
Foreign Business Activities in the USA US Real Estate Investments
October 30, 2003 - Phil Hodgen

New California Water’s Edge Law

California has just enacted a change to the water's edge election rules. If the Franchise Tax Board wants a piece of your multinational income (and they always do), you need to know about this. The new law makes it a bit harder to goof things up. It's a good thing. (Registered trademark, all rights reserved, Martha Stewart).
October 3, 2003 - admin

Reporting interest income paid to nonresidents (cont’d)

Currently, nonresidents can earn interest on U.S. bank deposits and the IRS isn't told a thing about it. There's a good reason for it: this helps U.S. banks compete internationally for deposits. The Treasury Department wants to change this. Here is an update to the story and a copy of the Treasury Department's letter to the U.S. Chamber of Commerce about the situation.
Nonresidents with US Activities US Real Estate Investments
October 3, 2003 - admin

Welcome to, v. 2

The old static HTML site is gone -- frames, tables, dozens of little .gifs -- everything. In its place is a Movable Type-powered site. The new site will allow and encourage evolution -- in how the site is organized, how it looks, and the content posted to it. Expect changes. And thanks, Adam, for the work.
Random Speeches, Publications, and Events
August 29, 2003 - admin

Interest paid to nonresidents: U.S. Chamber of Commerce doesn’t like proposed regulations

The IRS has an enquiring mind. Let’s just leave it at that. They like to know everything, because the IRS believes that all of us (the humble taxpayers) lie, cheat and steal.

At the moment, the IRS has a significant knowledge gap for foreigners. A nonresident of the United States can put money in a U.S. bank and earn interest on that deposit. The IRS will never, ever know about that interest, because the bank is not required to report bank interest earned by foreigners to the IRS.

A U.S. taxpayer, by contrast, will receive a Form 1099-INT at the end of the year, reporting the interest earned.... continue reading

Foreign Business Activities in the USA US Real Estate Investments