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The New Trump Bill And Foreign Investors
Tagged with: U.S. taxation
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…
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%…
Tagged with: FIRPTA
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”…
Tagged with: u.s. real estate investor
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…
Tagged with: FATCA
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.
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)…
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.
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”.
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