Menu

Blog   /   Nonresidents with US Activities

RSS
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
June 24, 2016 - Phil Hodgen

Trust Structures for Nonresident Real Estate Investors

Nongrantor trusts offer excellent tax performance for nonresident investors in U.S. real estate:

  • Estate tax risk is eliminated; and
  • Long term capital gains tax treatment applies to capital gains.

But everything has its price. These excellent tax results come at the expense of:

  • Significant set-up costs.
  • Significant operating costs.
  • Loss of control.
  • Capital — and capital gain — no longer belong to the investor.
Shameless Promotion: More on July 8, 2016

This episode of the Friday Edition gives you an overview of the benefits and risks. If you want more detail, you might consider an upcoming webcast/phone presentation on the topic.... continue reading

Friday Edition Nonresidents with US Activities US Real Estate Investments
June 10, 2016 - Phil Hodgen

Pooled Capital for Real Estate Investments by Nonresidents

Holding Structures for Pooled Nonresident Real Estate Investment

A group of nonresident individuals want to pool their money to buy commercial real estate in the United States.

They are going to buy decent-sized properties — commercial and office properties in the $5 million to $50 million range. This is serious money but not crazy huge.

How should they set this up for optimum U.S. tax results?

The Factors to Consider

The factors to consider are:

  • Estate tax. People die, and when they do, the Internal Revenue Service looks around to see if there are any assets can be taxed. Nonresident individual investors can — and should — eliminate that estate tax risk.
... continue reading
Friday Edition Nonresidents with US Activities US Real Estate Investments
January 28, 2016 - Debra Rudd

Is a late MTM election under the inbound immigrant rules possible?

Hello from Debra Rudd.

You are receiving this email because you are signed up for our bi-weekly “PFICs Only” newsletter, delivered to your electronic mailbox every other Thursday at 6:00am Pacific time. To stop receiving this newsletter, scroll to the bottom of this email and click “unsubscribe”. On the other hand, if you would like to see the other newsletters that we offer, go to hodgen.com/newsletters.

Is a late MTM election under the inbound immigrant rules possible?

This week’s topic comes from a question I received a while ago from an anonymous reader:

Does an immigrant to the US get to apply the basis step up/transition rule if they did not do a MTM election in their first year of US residence?

... continue reading
Nonresidents with US Activities PFIC and CFCs