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What happens to a nonresident who owns U.S. real estate and -- gasp -- does not report the rental income on a U.S. tax return?...

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...

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...

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...

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...

Hi from Phil, and welcome to the Friday Edition. Every other week you get something about International Tax from me. And every now and then,...

Hi it's Phil and welcome to the Friday Edition. If you want to stop getting these emails, click on the "unsubscribe" link at the bottom...

This is part of the Real Estate Series–episodes focused at helping nonresidents buy, hold, and sell U.S. investment properties–profitably. We All Die Our clients are...

I have been long silent on this topic but for those of you who need the information, here it is. Folding The Swiss government and...

TL;DR The train is headed straight at you. You cannot tell how far away it is. You can step off the tracks to safety. Alt:...

I received a call today from a reader in Florida. His question was about the branch profits tax and foreign investors in U.S. real estate....

Nonresidents who have U.S. rental real estate will usually make an election to have their rental income taxed as if they were residents of the...

  Upcoming speech I am going to be giving a one-hour high speed presentation at the 2011 Tax Update and Planning Conference sponsored by the...

This is a comment on another post on my blog. It is important to give this a more prominent platform, so I did a cut/paste...

Here is a September 1, 2010 opinion from the United States District Court in which a taxpayer, after pleading guilty to tax fraud and criminal...

If you are a nonresident of the United States and are considering real estate investments in the U.S., the first thought is "Where do I...

Comment: This little FAQ is a simple (for certain values of $SIMPLE) :-) explanation of the branch profits tax for nonresident investors in U.S. real...

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...

U.S. tax law says that a U.S. citizen -- no matter where he/she lives -- will be taxable on worldwide income. But if you're a...

Note: this is another answer for the accountants who took my all-day courses in Pleasanton in January. The "Net Election" is an election by a...