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December 2020 International Tax Lunch: Partnership Investment in US Real Estate by Nonresidents

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December 16, 2020 - Rachel Allen

December 2020 International Tax Lunch: Partnership Investment in US Real Estate by Nonresidents

International Tax Lunch: Partnership Investment in US Real Estate by Nonresidents

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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November 19, 2020 - Rachel Allen

November 2020 International Tax Lunch: Choosing a Holding Structure for Investment in U.S. Real Estate

International Tax Lunch: Choosing a Holding Structure for Investment in U.S. Real Estate

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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November 3, 2020 - Rachel Allen

October 2020 International Tax Lunch: Solving Individual Problems with Tax Treaties

International Tax Lunch: Solving Individual Problems with Tax Treaties

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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September 14, 2020 - Rachel Allen

September 2020 International Tax Lunch: Section 962 – Should I be Taxed as Corporation?

Section 962 – Should I be Taxed as Corporation?

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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August 21, 2020 - Rachel Allen

August 2020 International Tax Lunch: Guide to Global Intangible Low-Taxed Income

Guide to Global Intangible Low-Taxed Income

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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