Structuring Foreign Investment in U.S. Real Estate: Entity Selection and Transaction Structures
FIRPTA, Determining Individual vs. Entity Ownership Structures, Achieving Optimal Tax Treatment
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. real estate, outline best practices for determining the purchasing entity, and review tax planning opportunities in structuring the deal.
- Persons Subject to U.S. Taxation
- U.S. Citizens and Residents
- Non-resident Aliens
- U.S. Corporations
- Foreign Corporations
- Domestic U.S. Trusts
- Foreign Trusts
- U. S. Taxation of Foreign Persons
- U.S. Income Taxation
- U.S. Estate Tax
- U.S. Gift Tax
- Advantages and Disadvantages of Alternative Investment Structures
- Individual ownership
- Ownership by U.S. LLC
- Ownership by U.S. Corporation
- Ownership by Foreign Corporation
- Ownership by U.S. Subsidiary of Foreign Corporation
- Ownership by Foreign Trust
- Tax Strategies
- 1031 Exchange
- Portfolio Interest
- Shared Equity Mortgage
- International Tax Treaties
- Implications of the Tax Cuts and Jobs Act
The panel will review these and other key issues:
- What are the various tax consequences of a foreign person owning U.S. real estate in an individual capacity?
- What is the impact of blocker corporations and other intermediary entities on the tax treatment of foreign investment in U.S. real estate?
- How can the foreign investor leverage the 1031 exchange in purchasing U.S. real estate?
- What is the impact of tax reform on U.S. real estate investments by foreign entities?
William F. Griffin, Jr.
Davis Malm & D'Agostine
Mr. Griffin practices in the Banking and Credit, Business Law, and Real Estate and Environmental areas. He primarily... | Read More
Mr. Griffin practices in the Banking and Credit, Business Law, and Real Estate and Environmental areas. He primarily represents privately owned and publicly held businesses in a variety of business and real estate transactions. He has also acted as bond counsel in many tax-exempt bond financings.Close
Richard S. LeVine
Mr. LeVine's practice focuses on cross-border estate, gift and income tax planning for owners of privately held... | Read More
Mr. LeVine's practice focuses on cross-border estate, gift and income tax planning for owners of privately held companies and other high-net-worth U.S. and foreign individuals. He counsels clients on pre-immigration and pre-expatriation tax planning, offshore trusts and foundations deferred compensation planning for fund manager and structures involving life insurance. He has been heavily involved in advising clients on the IRS Voluntary Disclosure programs.Close