PODCAST: Richard S. Lehman discussing Claw-Backs at recent Stafford Publishing live webinar. Section 1341 “Claim of Right” Refunds Any lawyer involved in a clawback settlement agreement must, where possible, in the settlement agreement, distinguish between and earmark the two types…
Effective February 16, 2016 FIRPTA general withholding rate increases from 10% to 15% effective for closings on or after February 16, 2016 in the United States. Closing agents should adjust their procedures and forms to reflect this change. The 10%…
Income Tax Non Resident Alien Individuals and Foreign Corporations (“Foreign Investors”) that invest in U.S. real estate are taxed similar to U.S. Individual Taxpayers and U.S. Corporations on their U.S. real estate income. We will use the term “Foreign Investors”…
United States taxpayers, which include United States citizens, Green Card holders and alien individuals who are considered to be United States residents for U.S. tax purposes, who have interests in and/or control over unreported foreign bank accounts are waking up…
. . .U.S. estate taxes may be completely avoided if the individual foreign investor owns a foreign corporation that may in turn own the U.S. real estate.
This is principally an article about tax planning for the non resident alien individual and foreign corporate investor that is planning for larger size investments in United States real estate (“Foreign Investor”). That is investments of One Million Dollars ($1,000,000)…
This is an extremely important and valuable I.R.S. Program. It allows almost every American who has been afraid to step forward and disclose their foreign assets to the U.S. taxing authorities to do so with minimized penalties on unpaid taxes and unfiled information returns.
The Technical Advice Memorandum reviewed the term “export property” for DISC purposes in depth and determined in its holding that computer software could indeed be “export property”.
Tagged with: computer software exporting
, DISC Commissions
, DISC Distribution
, DISC Election
, DISC Pricing
, Export DISC
, Export Gross Receipts
, export profits
, Export Property
, internet sales
, Producer Loans
, richard s lehman
, software licenses
Question: Can a Foreign Investor use corporate entities to avoid the U.S. estate tax and the Branch Tax and pay only a single tax on gain from U.S. real estate? Answer: Yes, the Tiered Corporation is a typical investment entity…