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March 2021 International Tax Lunch: Foreign Owners of Domestic Corporations and Preparing Form 5472

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March 18, 2021 - Rachel Allen

March 2021 International Tax Lunch: Foreign Owners of Domestic Corporations and Preparing Form 5472

Foreign Owners of Domestic Corporations and Preparing Form 5472

Form 5472 filing requirements apply to foreign-owned domestic corporations and domestic disregarded entities, as well as foreign corporations engaged in a U.S. trade or business. Complex attribution rules mean that identifying the reporting requirements can be a difficult task, and the penalty risk is high. Learn how to identify when a Form 5472 is required, what types of attribution rules may apply and some of the major issues that need to be reported on Form 5472.

Presenter: Phil Hodgen

Materials: Dropbox

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February 15, 2021 - Rachel Allen

February 2021 International Tax Lunch: Asset Taxation During and After Expatriation

Asset Taxation During and After Expatriation

Covered expatriates are subject to the exit tax. There are several different ways that the exit tax is implemented. In this presentation, we will review how different types of assets will be taxed upon expatriation and in the aftermath. We will identify assets that create bad tax results or timing problems that lead to high tax rates, and we’ll discuss steps to avoid those problems. We will also review the tax paperwork you can expect to file after expatriation.

Presenter: Debra Rudd

Materials: Dropbox

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January 21, 2021 - Phil Hodgen

January 2021 International Tax Lunch: Net Worth Test for Expatriation

Net Worth Test for Expatriation

Expatriates have to navigate three tests to determine whether they will be covered expatriates. In this session, we will discuss the Net Worth Test in depth. How do you know what you own vs. what belongs to your spouse? What assets and liabilities are included? How do you value them? What can you do if your net worth is “too high”? Learn the basics and the not-so-basics in this Net Worth Test crash course.

Presenter: Debra Rudd

Materials: Dropbox

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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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