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March 30, 2010 - Phil Hodgen

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, in a wide-ranging interview on Monday.

Banks and property owners are going to be under increasing pressure.  Prices will drop.

Do your preparation now.  Maybe test the market a little.  Get ready, get smart.

You don’t want to be setting up your business models (what do I buy?... continue reading

Foreign Business Activities in the USA US Real Estate Investments
February 9, 2010 - Phil Hodgen

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 is interested in H.R. 4539, which was introduced on January 27, 2010, too bad. Nothing is there on the Ways & Means Committee’s website. Nor is there anything yet on the website for the Bill’s author, Rep. Joseph Crowley.)

And yeah. I’ll be writing something up for you on this proposed change to the tax laws.... continue reading

Foreign Business Activities in the USA Nonresidents with US Activities Speeches, Publications, and Events
January 19, 2010 - Phil Hodgen

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 emboldened to share with the U.S. government, and the information shared will be about you. And vice versa. This will be done under the guise of the Bogeyman du Jour (drug cartels, terrorists, etc.) but it will be done.

The IRS updated the Internal Revenue Manual in late December 2009 with a Memorandum titled “Interim Guidance on Interactions with Foreign Tax Officials.”... continue reading

Foreign Business Activities in the USA
December 15, 2009 - Phil Hodgen

Expatriation business is good, thanks in part to dumb tax policy

Today’s Wall Street Journal (link to the article is here, Rupert Murdoch, and be damned) there is non-tax verification of what I am seeing here.

What we’re seeing

We take people all the way through the process until they have no more U.S. passport and are completely–and legally–logged out of the U.S. tax system forever. Same thing for people with green cards. We take them all the way through the process. (Side note: at the California Society of CPA’s International Tax Conference last week in Costa Mesa a speaker asked a room of 100 people who had direct experience with Section 877A, the IRS rules for people who give up their citizenship or permanent resident status.... continue reading

Foreign Business Activities in the USA
December 14, 2009 - Phil Hodgen

HSBC/Geneva has client data stolen by former employee

We’ve heard this song before. Disgruntled bank employee grabs secret information about customers, spills the beans to the tax authorities in another country.

A couple of years ago it was Liechtenstein and the LGT Bank. Now it is HSBC in Geneva. This time it is French taxpayers who are feeling the heat.

The nut grafs:

A former employee of the bank stole client data between late 2006 and early 2007, the bank confirmed yesterday.

However, it insisted that only ten of the bank’s wealthiest customers had been affected by the theft, which was discovered during a period of police surveillance in 2008.

... continue reading
Foreign Business Activities in the USA US Real Estate Investments Voluntary Disclosure