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By Richard S. Lehman, Esq. Presented here is an article describing the U.S. Tax Treaty provisions that permit nonresident aliens to stay longer in the U.S. than is typically allowed and generally limited to at most 182 days. The relevant …
United States Tax Treaties, The Closer Connection Exception & Tiebreakers Read more »
The United States of America today is the investor’s dream.
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 …
PODCAST: Calculating Tax Benefits, Avoiding Double Taxation on Repayments and Claw-Backs Read more »
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% …
FIRPTA Withholding Rate To Increase To 15 Percent Read more »
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” …
Foreign Real Estate Investor Tax Planning Techniques: PART 1 (Advanced) Read more »
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 …
When dealing with FATCA, gather your team, a tax lawyer and an accountant Read more »
. . .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.
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? …
Frequently Asked Questions about Non-Resident Aliens for U.S. Tax Purposes Read more »