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How can you structure foreign investments in U.S. real estate when you have a group of foreign investors, or a mix of foreign and domestic investors? Capital gains, rental income, and estate tax considerations for the foreign investors are significantly different, and a partnership’s tax compliance is more difficult with foreign partners. This session reviews some methods for structuring foreign equity and debt investment into U.S. real estate, in group settings — rather than the lone investor situation.
Presenter: Phil Hodgen
Materials: Dropbox
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Foreign investors can own U.S. real estate using a variety of holding structures. There is no simple and obviously “best” choice. This session compares taxation of rental income and capital gain, as well as estate and gift tax exposure for a foreign investor. With the 2017 tax law changes, corporations are now much more interesting than they used to be.
Presenter: Phil Hodgen
Materials: Dropbox
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Tax treaties between the United States and other countries cover a variety of topics, including income. The treaties create a parallel Federal tax law to the Internal Revenue Code, and sometimes it is useful to opt out of the Code and into the treaties for tax planning purposes. In this presentation, we will focus on individual taxpayers: when are tax treaty elections permitted, how you make an election, and how you decide whether making a treaty election is a good idea.
Presenter: Phil Hodgen
Materials: Drop box
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The new international tax rules now make most foreign corporation income immediately taxable to U.S. shareholders (via the Subpart F and GILTI rules). Section 962 gives individual taxpayers an election to be taxed on Subpart F income and GILTI at corporate tax rates (21%) rather than individual tax rates (as high as 37%). Should individual shareholders make this election? (Hint: the election’s consequences are not all rainbows and unicorns.)
Presenter: Phil Hodgen
Materials: Dropbox
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U.S. shareholders of foreign corporations have a new pass-through income category to contend with: GILTI. Except for capital-intensive companies, this has the effect of making foreign operating income immediately taxable to U.S. shareholders. This session explores the new rules. What is GILTI? How will it affect U.S. shareholders? What countermeasures are available?
Presenter: Phil Hodgen
Materials: Dropbox
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