This webinar introduces some of the most important tax issues that non-US investors in U.S. real estate should consider.
You will learn:
- Introductions to US Real Estate investment by Foreign Investor
- FDAP income (Not trade or business income)
- Effectively Connected Income (ECI)
- Foreign Investment in Real Property Tax Act of 1980 (FIRPTA)
- Choice of proper investment structure and tax planning
- Tax Implications for:- Rental income tax- Capital Gain Tax on the eventual disposition of property- Estate/Gift tax consequences
- Other consideration- Anonymity – Nondisclosure of the identity- Assets protection- The simplicity of the structure balances against complexity costs.
GEO NECF 2015 - Exploring the Challenges of Tax Compliance and the W-8BENAndrea Huck-Esposito
With the many complex brokerage challenges servicing international participants - foreign jurisdictional restrictions, FATCA compliance, IRS guidelines and many more, having an understanding of the shared ownership between you and your broker can help navigate the difficulties of ensuring your participants’ compliance with tax regulations. In this presentation, Andrea Kagan, Solium, will be joined by Brian Burke of TD Ameritrade and Andrew Gerwirtz of KPMG. The trio will discuss their views on the shared ownership of understanding the in and outs of the W-8 and how it impacts international employees and a mobile workforce.
International Taxation – US Citizen and Green Card Holder (Resident Alien)Smart Accountants
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our webinar series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
Are you considering investing in U.S. real estate? Don't forget about FIRPTA - the Foreign Investment in Real Property Tax Act. This federal law requires foreign persons to pay taxes on the sale of U.S. real estate, but there are ways to avoid or reduce FIRPTA withholding.
💡One common way to do this is by structuring the sale as a like-kind exchange under Section 1031 of the Internal Revenue Code. This allows foreign investors to defer paying taxes on the sale of their U.S. property by reinvesting the proceeds into another qualifying property.
🚀Another option is to work with experienced professionals who can help you navigate the rules and requirements of FIRPTA and explore other strategies for minimizing your tax liability.
👉Don't let FIRPTA catch you off guard! Contact us today to learn how we can help you avoid unnecessary taxes and make the most of your U.S. real estate investments.
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our PPT series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
Numerous US individuals own overseas assets or have an interest in them. The IRS may penalize these taxpayers if they fail to report these assets on their tax filings. Consequently, the streamlined filing compliance procedure exists to assist these individuals with:
– A streamlined process to file delinquent or amended tax returns;
– Resolving tax and penalty procedures for filing delinquent or amended returns; and
– Resolving penalty and tax obligations
This webinar will guide you through the complexities of Streamlined Filing Compliance Procedures and make your US Tax Journey Exponentially easier!
Takeaways:
Topics that we will cover in the upcoming webinar:
1. Introduction to Streamlined filing
2. Eligibility Criteria for Streamlined Filing
3. Types of Streamlined Filing
– Streamlined Foreign Offshore Procedures
– Streamlined Domestic Procedures
4. Other rules and regulations
5. FAQs, and much more
Who Attended?
- US Citizens Living in the US and Outside
- CPAs, EAs, CAs, ACCAs
- Tax and Accounting Professionals with US Citizens as their clients
GEO NECF 2015 - Exploring the Challenges of Tax Compliance and the W-8BENAndrea Huck-Esposito
With the many complex brokerage challenges servicing international participants - foreign jurisdictional restrictions, FATCA compliance, IRS guidelines and many more, having an understanding of the shared ownership between you and your broker can help navigate the difficulties of ensuring your participants’ compliance with tax regulations. In this presentation, Andrea Kagan, Solium, will be joined by Brian Burke of TD Ameritrade and Andrew Gerwirtz of KPMG. The trio will discuss their views on the shared ownership of understanding the in and outs of the W-8 and how it impacts international employees and a mobile workforce.
International Taxation – US Citizen and Green Card Holder (Resident Alien)Smart Accountants
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our webinar series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
Are you considering investing in U.S. real estate? Don't forget about FIRPTA - the Foreign Investment in Real Property Tax Act. This federal law requires foreign persons to pay taxes on the sale of U.S. real estate, but there are ways to avoid or reduce FIRPTA withholding.
💡One common way to do this is by structuring the sale as a like-kind exchange under Section 1031 of the Internal Revenue Code. This allows foreign investors to defer paying taxes on the sale of their U.S. property by reinvesting the proceeds into another qualifying property.
🚀Another option is to work with experienced professionals who can help you navigate the rules and requirements of FIRPTA and explore other strategies for minimizing your tax liability.
👉Don't let FIRPTA catch you off guard! Contact us today to learn how we can help you avoid unnecessary taxes and make the most of your U.S. real estate investments.
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our PPT series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
Numerous US individuals own overseas assets or have an interest in them. The IRS may penalize these taxpayers if they fail to report these assets on their tax filings. Consequently, the streamlined filing compliance procedure exists to assist these individuals with:
– A streamlined process to file delinquent or amended tax returns;
– Resolving tax and penalty procedures for filing delinquent or amended returns; and
– Resolving penalty and tax obligations
This webinar will guide you through the complexities of Streamlined Filing Compliance Procedures and make your US Tax Journey Exponentially easier!
Takeaways:
Topics that we will cover in the upcoming webinar:
1. Introduction to Streamlined filing
2. Eligibility Criteria for Streamlined Filing
3. Types of Streamlined Filing
– Streamlined Foreign Offshore Procedures
– Streamlined Domestic Procedures
4. Other rules and regulations
5. FAQs, and much more
Who Attended?
- US Citizens Living in the US and Outside
- CPAs, EAs, CAs, ACCAs
- Tax and Accounting Professionals with US Citizens as their clients
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Americans face many investing challenges while living in the UK. They require help with keeping constant vigilance on rules and regulations. Get in touch with a Maseco financial advisor expert today to see how we can help you get a handle on your domestic and foreign investments.
While residing in the UK, US citizens have numerous investing hurdles. They must remain vigilant about laws and regulations at all times. Contact a Maseco US UK financial advisor today to learn how we can assist you in managing your domestic and international investments.
This presentation includes an overview of tax changes from 2012 and what's new in 2013.
For more information about our tax services, visit www.cbiz.com
Current Tax Planning Techniques in U.S. and International TransactionsWinston & Strawn LLP
The Real Deal webinar, “Current Tax Planning Techniques in U.S. & International Transactions,” focused on the tax issues relating to both domestic and cross-border transactions. In the domestic area, we reviewed structuring and other common tax issues in the acquisition of domestic C corporations, S corporations, and partnerships. In the international area, we covered structuring issues relating to acquisitions of foreign targets by U.S. corporations, as well as current developments related to inversions in light of IRS Notice 2014-52 and new IRS Notice 2015-79.
When it comes to getting your clients to the United States you’re the master. But what happens when that conversation turns to the client’s financial planning? Global migration can lead to some tricky tax situations which may not always get the attention they deserve. In this webinar, senior accountants from Moss Adams LLP will address some tax issues that every immigration lawyer should be aware of.
In this presentation, our speakers will discuss planning for entry into the U.S. tax system, including a high-level overview of income, and estate and gift tax considerations. We will address the U.S. foreign disclosure rules and the US anti-deferral regimes. And we will briefly touch on tax planning prior to the surrender of U.S. citizenship or long-term permanent resident status.
Estate and Gift Tax Issues.
Planning for move to U.S.
Estate/gift tax residency.
Estate/gift tax applicability for NRA’s and for U.S. residents.
Planning for U.S. gift/estate tax applicability – considerations of trusts/gifting before a move.
Planning for the U.S. foreign disclosure rules – streamlining/consolidation of foreign assets/entities before a move.
Considerations Prior to moving to U.S.
Considerations related to negotiating compensation arrangements/benefits/tax equalization agreements/etc. before moving to the U.S.
Determining taxation and differences of taxation for U.S. residents vs. non-residents.
U.S./State taxation of foreign nationals.
U.S. residency vs non-residency for income tax purposes.
U.S. taxation of U.S. persons vs NRAs.
Substantial Presence Test.
Closer Connection Exception.
Dual Status Returns.
First Year Elections.
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Americans face many investing challenges while living in the UK. They require help with keeping constant vigilance on rules and regulations. Get in touch with a Maseco financial advisor expert today to see how we can help you get a handle on your domestic and foreign investments.
While residing in the UK, US citizens have numerous investing hurdles. They must remain vigilant about laws and regulations at all times. Contact a Maseco US UK financial advisor today to learn how we can assist you in managing your domestic and international investments.
This presentation includes an overview of tax changes from 2012 and what's new in 2013.
For more information about our tax services, visit www.cbiz.com
Current Tax Planning Techniques in U.S. and International TransactionsWinston & Strawn LLP
The Real Deal webinar, “Current Tax Planning Techniques in U.S. & International Transactions,” focused on the tax issues relating to both domestic and cross-border transactions. In the domestic area, we reviewed structuring and other common tax issues in the acquisition of domestic C corporations, S corporations, and partnerships. In the international area, we covered structuring issues relating to acquisitions of foreign targets by U.S. corporations, as well as current developments related to inversions in light of IRS Notice 2014-52 and new IRS Notice 2015-79.
When it comes to getting your clients to the United States you’re the master. But what happens when that conversation turns to the client’s financial planning? Global migration can lead to some tricky tax situations which may not always get the attention they deserve. In this webinar, senior accountants from Moss Adams LLP will address some tax issues that every immigration lawyer should be aware of.
In this presentation, our speakers will discuss planning for entry into the U.S. tax system, including a high-level overview of income, and estate and gift tax considerations. We will address the U.S. foreign disclosure rules and the US anti-deferral regimes. And we will briefly touch on tax planning prior to the surrender of U.S. citizenship or long-term permanent resident status.
Estate and Gift Tax Issues.
Planning for move to U.S.
Estate/gift tax residency.
Estate/gift tax applicability for NRA’s and for U.S. residents.
Planning for U.S. gift/estate tax applicability – considerations of trusts/gifting before a move.
Planning for the U.S. foreign disclosure rules – streamlining/consolidation of foreign assets/entities before a move.
Considerations Prior to moving to U.S.
Considerations related to negotiating compensation arrangements/benefits/tax equalization agreements/etc. before moving to the U.S.
Determining taxation and differences of taxation for U.S. residents vs. non-residents.
U.S./State taxation of foreign nationals.
U.S. residency vs non-residency for income tax purposes.
U.S. taxation of U.S. persons vs NRAs.
Substantial Presence Test.
Closer Connection Exception.
Dual Status Returns.
First Year Elections.
how can i use my minded pi coins I need some funds.DOT TECH
If you are interested in selling your pi coins, i have a verified pi merchant, who buys pi coins and resell them to exchanges looking forward to hold till mainnet launch.
Because the core team has announced that pi network will not be doing any pre-sale. The only way exchanges like huobi, bitmart and hotbit can get pi is by buying from miners.
Now a merchant stands in between these exchanges and the miners. As a link to make transactions smooth. Because right now in the enclosed mainnet you can't sell pi coins your self. You need the help of a merchant,
i will leave the telegram contact of my personal pi merchant below. 👇 I and my friends has traded more than 3000pi coins with him successfully.
@Pi_vendor_247
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
how to sell pi coins in all Africa Countries.DOT TECH
Yes. You can sell your pi network for other cryptocurrencies like Bitcoin, usdt , Ethereum and other currencies And this is done easily with the help from a pi merchant.
What is a pi merchant ?
Since pi is not launched yet in any exchange. The only way you can sell right now is through merchants.
A verified Pi merchant is someone who buys pi network coins from miners and resell them to investors looking forward to hold massive quantities of pi coins before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
how to sell pi coins effectively (from 50 - 100k pi)DOT TECH
Anywhere in the world, including Africa, America, and Europe, you can sell Pi Network Coins online and receive cash through online payment options.
Pi has not yet been launched on any exchange because we are currently using the confined Mainnet. The planned launch date for Pi is June 28, 2026.
Reselling to investors who want to hold until the mainnet launch in 2026 is currently the sole way to sell.
Consequently, right now. All you need to do is select the right pi network provider.
Who is a pi merchant?
An individual who buys coins from miners on the pi network and resells them to investors hoping to hang onto them until the mainnet is launched is known as a pi merchant.
debuts.
I'll provide you the Telegram username
@Pi_vendor_247
when will pi network coin be available on crypto exchange.DOT TECH
There is no set date for when Pi coins will enter the market.
However, the developers are working hard to get them released as soon as possible.
Once they are available, users will be able to exchange other cryptocurrencies for Pi coins on designated exchanges.
But for now the only way to sell your pi coins is through verified pi vendor.
Here is the telegram contact of my personal pi vendor
@Pi_vendor_247
Introduction to Indian Financial System ()Avanish Goel
The financial system of a country is an important tool for economic development of the country, as it helps in creation of wealth by linking savings with investments.
It facilitates the flow of funds form the households (savers) to business firms (investors) to aid in wealth creation and development of both the parties
what is the future of Pi Network currency.DOT TECH
The future of the Pi cryptocurrency is uncertain, and its success will depend on several factors. Pi is a relatively new cryptocurrency that aims to be user-friendly and accessible to a wide audience. Here are a few key considerations for its future:
Message: @Pi_vendor_247 on telegram if u want to sell PI COINS.
1. Mainnet Launch: As of my last knowledge update in January 2022, Pi was still in the testnet phase. Its success will depend on a successful transition to a mainnet, where actual transactions can take place.
2. User Adoption: Pi's success will be closely tied to user adoption. The more users who join the network and actively participate, the stronger the ecosystem can become.
3. Utility and Use Cases: For a cryptocurrency to thrive, it must offer utility and practical use cases. The Pi team has talked about various applications, including peer-to-peer transactions, smart contracts, and more. The development and implementation of these features will be essential.
4. Regulatory Environment: The regulatory environment for cryptocurrencies is evolving globally. How Pi navigates and complies with regulations in various jurisdictions will significantly impact its future.
5. Technology Development: The Pi network must continue to develop and improve its technology, security, and scalability to compete with established cryptocurrencies.
6. Community Engagement: The Pi community plays a critical role in its future. Engaged users can help build trust and grow the network.
7. Monetization and Sustainability: The Pi team's monetization strategy, such as fees, partnerships, or other revenue sources, will affect its long-term sustainability.
It's essential to approach Pi or any new cryptocurrency with caution and conduct due diligence. Cryptocurrency investments involve risks, and potential rewards can be uncertain. The success and future of Pi will depend on the collective efforts of its team, community, and the broader cryptocurrency market dynamics. It's advisable to stay updated on Pi's development and follow any updates from the official Pi Network website or announcements from the team.
Resume
• Real GDP growth slowed down due to problems with access to electricity caused by the destruction of manoeuvrable electricity generation by Russian drones and missiles.
• Exports and imports continued growing due to better logistics through the Ukrainian sea corridor and road. Polish farmers and drivers stopped blocking borders at the end of April.
• In April, both the Tax and Customs Services over-executed the revenue plan. Moreover, the NBU transferred twice the planned profit to the budget.
• The European side approved the Ukraine Plan, which the government adopted to determine indicators for the Ukraine Facility. That approval will allow Ukraine to receive a EUR 1.9 bn loan from the EU in May. At the same time, the EU provided Ukraine with a EUR 1.5 bn loan in April, as the government fulfilled five indicators under the Ukraine Plan.
• The USA has finally approved an aid package for Ukraine, which includes USD 7.8 bn of budget support; however, the conditions and timing of the assistance are still unknown.
• As in March, annual consumer inflation amounted to 3.2% yoy in April.
• At the April monetary policy meeting, the NBU again reduced the key policy rate from 14.5% to 13.5% per annum.
• Over the past four weeks, the hryvnia exchange rate has stabilized in the UAH 39-40 per USD range.
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
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Empowering the Unbanked: The Vital Role of NBFCs in Promoting Financial Inclu...Vighnesh Shashtri
In India, financial inclusion remains a critical challenge, with a significant portion of the population still unbanked. Non-Banking Financial Companies (NBFCs) have emerged as key players in bridging this gap by providing financial services to those often overlooked by traditional banking institutions. This article delves into how NBFCs are fostering financial inclusion and empowering the unbanked.
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NO1 Uk Black Magic Specialist Expert In Sahiwal, Okara, Hafizabad, Mandi Bah...
Introduction to Taxation of Foreign Investment in U.S. Real Estate
1.
2. • Introductions to US Real Estate investment by Foreign Investor
• FDAP income (Not trade or business income)
• Effectively Connected Income (ECI)
• Foreign Investment in Real Property Tax Act of 1980 (FIRPTA)
• Choice of proper investment structure and tax planning
• Tax Implications for
o Rental income tax
o Capital Gain tax on eventual disposition of property
o Estate/Gift tax consequences
7. Other consideration
o Anonymity – Non disclosure of identity
o Assets protection
o Simplicity of structure to balance against complexity costs.
Webinar Overview:
3.
4. Who are Foreign Investors?
A Foreign investor is a non-resident alien individual who is
• Not a U.S. Citizen
• Does not have Green Card
• Does not meet the “Substantial Presence Test”:
To meet this test, a person must be physically present in the United States
on at least:
• 31 days during the current year, and
• 183 days during the 3-year period that includes the current year and the
2 years immediately before that, considering:
• All the days a person was present in the current year, and
• One-Third (1/3) of the days a person was present in the first year before
the current year, and
• One-sixth (1/6) of the days a person in the second year before the
current year.
A Foreign investor is also foreign entity (Corporation, trust, partnership etc
5. • Fixed or determinable annual or periodic income (FDAP) income
also subject to tax by the US
• This includes interest, dividends, rent, etc.
• The default classification for rental income is FDAP income.
• FDAP income is generally subject to a flat 30% tax (or lower treaty)
rate on “Gross income” and deductions are not permitted.
• Non-Residents are taxed in the US on income effectively connected
with a US trade or business (ECI) on a NET basis
• Trade or business is not defined in Code/regulations but is any
profit motive activities carried on in the US on a regular, substantial,
and continuous basis are classified as trade or business for these
purposes.
FDAP income and Effectively
Connected Income
6. Nonresident are permitted to file an election
under Sec. 871(d) for individual and Sec. 882(d)
for corporations to treat income generated by
US real property as ECI
Nonresidents – Election to treat
real property income as ECI:
Property must be income producing for
election to be made
Election cannot made if property producing
expenses but no income
Election remains in effect all subsequent years
until revocation
7. Reg. 1.871-10(d)(1)(ii)-
ECI election
• Schedule of all the nonresident’s US real property (and level of
ownership)
• Location of each real property
• List of improvements, and
• Information on prior net elections
• Real estate held by partnership – election made by partners (rather than at
the partnership level)
8. Disposition of US Real Property
Interest - FIRPTA General Rules
The sale, exchange, or transfer of United States Real Property by foreigners
may be subject to special withholding. The amount of withholding required is
typically 15% of the sales price.
IRC 1445 - Buyer is responsible for making sure the IRS receives the
withholding Tax within the 20 days period.
Payment of withholding tax is sent to IRS with form 8288 and 8288-A
Part I is competed if the buyer is an individual person
Part II is completed if an “Entity” is the buyer
9.
10.
11. • Withholding is not the tax itself, and hence less taxable gain or loss on sale
causes cash flow problem due to withholding.
• This exemption is exemption/reduction from withholding and not from tax/tax
filing.
• Under some circumstances, withholding may be reduced or eliminated.
• Buyer intends to use the property as residence at least 50% of time in 2 years from
closing
• Buyer must be an individual
Sales price $300,000 or less - 0% Withholding Tax
Sales price 300,001 - $1,000,000 - 10% Withholding Tax
Sales price more than $1,000,000 - 15% Withholding Tax
Withholding
Exemption/Reduction
12. FIRPTA withholding Options:
• Request a Reduction of Withholding Certificate Prior to Closing
• Allow Withholding to Occur and Request a Claim of Refund by filing the Non-Resident Income Tax
Return
• Treas. Regulation 1.1445-3
• Treas. Regulation 1.1445-6
• Rev. Proc. 2000-35
• IRS Publication 515
• Prepare Form 8288-B
• Prepare Attachment to Form 8288-B
• Calculation of capital gain tax
• If rental property, calculation of depreciation recapture and suspended passive losses, if
applicable.
Request a Reduction of Withholding
Certificate – Form 8288-B
13. • File Form 1040NR
• Must have stamped Copy A of Form 8288-A to get refund back from IRS
• If foreign person does not have ITIN they need to obtain one
Allow Withholding to Occur
and Request a Claim of
Refund by filing the Non-
Resident Income Tax Return
14. If a Non resident owns US Real
Property through 100% owned
LLC, can they avoid FIRPTA?
• The answer is NO
• Starting in 2017, all foreign-owned Single-Member LLCs that are Disregarded Entities are
now treated as Corporations for federal reporting requirements (submitting information) to
the IRS. This doesn’t mean the LLC is paying tax like a Corporation, but rather, it’s simply
reporting information like a Corporation.
• So, you may have to file Form 1120 page 1 and Form 5472 – Failure to file penalty is
$25,000
• In addition, there is New FinCen Form for Beneficial Ownership Disclosure starting in
2022. – Failure to file penalty is $10,000
15. • When a Nonresident makes a 6013(g) election to file jointly with their US spouse,
they are agreeing to be taxes as a US tax resident.
• Reg §1.897-9T – Resident alien individuals includes nonresident alien who has
elected to be resident under Code sec 6013(g).
• IRC 121 allows an individual taxpayer to exclude up to $250,000 (or $500,000 if
married) of gain if they lived in Primary Residence for two out of the last five
years.
If I make a 6013(g) election
will this exempt me from
FIRPTA?
Does the IRC 121 Exclusion
apply to Non-Residents?
16. Estate Tax:
• -Nonresident individuals subject to tax on all property located within the US
• -Shares of a domestic corporation are subject to estate tax but shares of foreign
corporation are not.
• Some exceptions: Bank account not used in US trade or business, securities generating
portfolio interest
• Nonresident individuals receive a $60,000 estate tax exclusion with maximum 40% tax
rate.
Gift Tax:
• Nonresident normally are subject to gift tax on lifetime gifts of tangible property within the
US
• No specific gift tax exclusion for nonresident individuals, thought the $16,000 per donee
annual exclusion is available
Nonresident individual – Transfer
Taxes
17. • Nonresident who live, work, or own property in the US need to have a clear understanding of the potential
implications of the US estate and gift tax rules.
• There are multiple types of ownership options available:
Structuring Nonresident US Real Estate
Investments
18.
19. Advantage
• Graduated individual tax rates for rental income - 10%-37%
• Long term Capital Gains tax rate 0%-20%
• No Branch Tax Concern
Disadvantage
• Gift / Estate Tax applies
• Unlimited Personal Liability
• Disclosure of ownership
OPTION 1 – Individual ownership
20. Advantage
• Graduated individual tax rates for rental income - 10%-37%
• Long term Capital Gains tax rate 0%-20%
• No Branch Tax Concern
• Limited Personal Liability
• Personal Identity Protection
Disadvantage
• Gift / Estate Tax applies
OPTION 2 – Limited Liability Company
21. Advantage
• Flat Corporate tax rate of 21%
• No Branch Tax Concern
• Limited Personal Liability
• Personal Identity Protection
• No gift tax – IRC 2501(a)(2) – US situated intangible property
including stock of US corp is not subject to gift tax
Disadvantage
• Estate Tax applies
• Capital Gain taxable as ordinary income
• Double taxation - Dividend taxable
OPTION 3 – U.S. Corporation
22. Advantage
• Flat Corporate tax rate of 21%
• No Gift or Estate Tax
• Limited Personal Liability
• Personal Identity Protection
Disadvantage
• Branch Profit Tax
• Capital Gain taxable as ordinary income
• Double taxation - Dividend taxable
OPTION 4 - Foreign corporation (Not with
Inheritance Tax Treaty country)
23. • The asset in the decedent’s gross estate is stock/shares in a foreign
corporation. Foreign corporation stock/ shares are a foreign situated asset
and are excluded from the gross estate.
• BPT can be avoided with proper tax planning. BPT can be avoided if the
death tax treaty (inheritance tax treaty) exists.
• At present Death, tax treaties are in effect with the following countries:
Australia, Greece, Austria, Ireland, Canada, Italy, Denmark, Japan, Finland,
Netherlands, France, South Africa, Germany, Switzerland, United Kingdom.
• Exist the USA - Form 8848 - BPT does not apply in the year that a foreign
corporation terminates all US business activities.
Why Foreign Corporation works:
24. Advantage
• Flat Corporate tax rate of 21%
• No Estate or Gift Tax
• No Branch Profit Tax
• Personal Identity Protection
Disadvantage
• Capital Gain taxable as ordinary income
• Double taxation - Dividend taxable
OPTION 5 – Tiered Corporate
Entities
25. Advantage
• No Estate Tax
• No Branch Profit Tax
• Long term Capital Gains tax rate 0%-20%
Disadvantage
• Give up ownership and control of assets
OPTION 6 – Non Grantor
Trust
26. • No assets are includable in the decedent’s gross estate. IRC 2031.
• Settlor: The Settlor is the person who creates the trust by placing a particular
asset that s/he owns into the trust, which are managed by trustee for the
benefit of beneficiary
How irrevocable trust eliminates
estate tax:
28. For those interested in learning
more, asking questions or signing
up for one of our groups or
trainings,
NEXT STEPS:
Stay in the meeting after the end
OR schedule some time to talk:
Email: info@smartaccts.com | Phone: +1 850 788 2090