U.S.-Latin America Tax Planning for Investors and Companies: Tax Strategies, Compliance Requirements, Treaty Operations
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax counsel with a comprehensive guide to tax planning challenges and opportunities for clients who have or are seeking a tax presence in both the US and Latin America. The panel will discuss recent US-Chile tax treaty provisions that govern tax and fiduciary rules, strategies for minimizing the US tax impact of foreign-source ordinary and capital income before establishing tax residency in the US. The webinar will focus on US tax and other consequences for Latin American clients with or seeking a US tax presence and U.S. taxpayers with Latin America-based assets.
Outline
- Residency and tax consequences
- Tax rules that apply to foreign investors in U.S. real estate or businesses
- Investment structure alternatives and their tax consequences
- Pre-immigration planning goals
- Minimizing transfer tax impact
Benefits
The panel will review these and other key issues:
- What are the crucial considerations in wealth preservation for a foreign individual becoming a U.S. resident for tax purposes?
- What are the tax implications of purchasing U.S. assets individually vs. through an LLC vs. a blocker corporation or a trust?
- What are the tax reporting obligations for non-U.S. owners of U.S. assets?
- How does FIRPTA compliance vary between different ownership structures?
- What are the crucial considerations in wealth preservation for a foreign individual becoming a U.S. resident for tax purposes?
- How to avoid anti-deferral rules in pre-immigration transactions
Faculty
James A. Guadiana
Partner
Greenspoon Marder
Mr. Guadiana is a partner in the Tax practice group at Greenspoon Marder LLP. He is an experienced practitioner in... | Read More
Mr. Guadiana is a partner in the Tax practice group at Greenspoon Marder LLP. He is an experienced practitioner in virtually all areas of taxation. Mr. Guadiana serves as an advisor to public and privately-held multinational companies and investment firms with regard to their operations and investments in the United States and has extensive experience as a tax advisor to a number of public corporations listed on the London, Hong Kong, and Toronto stock exchanges. He is respected domestically and internationally for his ability to identify and resolve unique and complex tax issues in domestic and cross-border investments in a number of different areas of tax law. Mr. Guadiana has also advised both investment management firms and foreign investors in structuring lending programs so as to avoid being treated as the conduct of a “trade or business,” thereby enabling the foreign investor to minimize or avoid U.S. taxation.
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Julian A. Fortuna
Partner
Greenspoon Marder
Mr. Fortuna is a partner in Greenspoon Marder’s Corporate & Business practice group. With over 30 years of... | Read More
Mr. Fortuna is a partner in Greenspoon Marder’s Corporate & Business practice group. With over 30 years of legal experience, he concentrates his practice on domestic and international tax, business and estate planning, employee benefits, and executive compensation matters. Mr. Fortuna has substantial experience representing clients in the entertainment, higher education, clean energy, health care, hospitality, non-profit, manufacturing, retail, and real estate industries.
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