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December 9, 2016 - Phil Hodgen

Who’s On the Hook for Withholding Tax Failures?

This week I want to cover a real estate situation, and the perils of being a withholding agent when there is a foreign seller of U.S. real estate.

Foreign Corporation as Seller

From time to time I see foreign corporations as direct owners of U.S. real estate. This can work from a U.S. tax point of view (i.e., it can block the application of estate tax on the real estate if the shareholder dies).

But it creates a host of practical problems. And solving those practical problems will sometimes beget more practical problems.

This time I am going to explore the fine points of withholding tax on the sale of U.S.... continue reading

Friday Edition Nonresidents with US Activities US Real Estate Investments
August 24, 2016 - Phil Hodgen

Why Tax Practitioners Cannot Cash Your Refund Check

People who file Form 1040NR (as nonresidents of the United States) will sometimes receive a tax refund.  Sometimes it is large, sometimes it is small.

The IRS, by default, issues a paper check for refunds.

It will shock you to discover that sometimes paper checks take a long time to reach their overseas destination.  Sometimes the paper checks never arrive.  Or sometimes it is a big hassle to deposit the U.S. dollar denominated check into a bank account overseas.  Or it costs a significant amount in bank fees to get this done.

In short, paper checks are an abomination.

It is possible to have refunds deposited directly to your bank account.... continue reading

Nonresidents with US Activities Random
August 19, 2016 - Phil Hodgen

Nonresidents Buying U.S. Hedge Funds: How it Works

Hello again and welcome to the Friday Edition. Every other Friday, you get some international tax . . . ermmm . . . stuff from me, Phil Hodgen. You subscribed, so don’t blame me. 🙂

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Too Long; Didn’t Read

In a hurry?

  • U.S. income tax results are great for most hedge fund investments made by nonresidents.
... continue reading
Friday Edition Nonresidents with US Activities
August 5, 2016 - Phil Hodgen

Avoiding Banking Problems with Corporate Reorganizations

Hello again, and welcome to the Friday Edition. More international tax goodies this Friday and every other Friday.

It’s Phil Hodgen and you signed up for this road trip. (I never add people to the mailing list — I hate getting spam and I will not inflict it on others). If you want to stop getting this, there is an unsubscribe link at the bottom of this email that will do the trick.

Nonresident Seller and No U.S. Bank Account

This week’s episode is for nonresident investors in U.S. real estate. Specifically, I am going to talk about an expedient method I have used before (and will use again) to get around a banking problem.... continue reading

Friday Edition Nonresidents with US Activities US Real Estate Investments
July 22, 2016 - Phil Hodgen

Former green card holder returning to the United States as a visitor

If you sign up for one of my email newsletters, you will get a bot-response from me, thanking you for signing up.  But if you ask a question, the response is remarkably lifelike, because I actually write the answer.  🙂

Today reader S.J. signed up and here is what he wanted to know.  I have edited his comments slightly for formatting and clarity, but mostly to hide identifying information.

1 – What’s the single most important question you have about international tax?

I abandoned my LPR green card in ______, 2015 (delivered my Green Card with Form I-407 to the US embassy) and was given a visitor visa.

... continue reading
Expatriation Nonresidents with US Activities