Category: – English

English

PODCAST: Calculating Tax Benefits, Avoiding Double Taxation on Repayments and Claw-Backs

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

Posted in - English, Ponzi Schemes & Tax Loss

FIRPTA Withholding Rate To Increase To 15 Percent

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%

Posted in - English, Foreign Investors in United States Real Estate Tagged with:

Foreign Real Estate Investor Tax Planning Techniques: PART 1 (Advanced)

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”

Posted in - English, Foreign Investors in United States Real Estate, United States Taxation of Foreign Investors Tagged with:

When dealing with FATCA, gather your team, a tax lawyer and an accountant

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

Posted in - English, Settling with the IRS Tagged with:

Tax Planning for Foreign Investors Acquiring Smaller ($500,000 and under) United States Real Estate Investments

. . .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.

Posted in - English, Foreign Investors in United States Real Estate, United States Taxation of Foreign Investors Tagged with: , , ,

Tax Planning for Foreign Investors Acquiring Larger (One Million Dollars and over) United States Real Estate Investments

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)

Posted in - English, Foreign Investors in United States Real Estate, United States Taxation of Foreign Investors Tagged with: , , , , , ,

The new IRS Streamlined Filing Compliance Procedure explained by United States Tax Attorney Richard S. Lehman, Esq.

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.

Posted in - English, IRS Amnesty Tagged with: , , ,

Frequently Asked Questions about Non-Resident Aliens for U.S. Tax Purposes

Non Resident Alien Individuals and United States Income Tax QUESTION: The U.S. has a special tax regime for individuals who are not “tax residents” of the United States. What is the definition of a “nonresident Alien” for U.S. tax purposes?

Posted in - English, Pre-immigration income tax planning, United States Taxation of Foreign Investors Tagged with: ,

IC-DISC and United States Exporting of Computer Software, Internet Sales and Licenses

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”.

Posted in - English, U.S. Taxation Articles (Domestic) Tagged with: , , , , , , , , , , , , ,

Tax planning techniques for the foreign real estate investor in the United States

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

Posted in - English, Foreign Investors in United States Real Estate, United States Taxation of Foreign Investors