Real Estate Holding Structures for Foreign Investors: Income and Estate Tax Implications of U.S. and Foreign Entities
Direct Investments, Partnerships, Corporations, Trusts
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will point out the importance of selecting an appropriate holding structure for U.S. real estate owned by foreign taxpayers. Our panel of veteran international tax authorities will weigh the benefits and caveats of choosing a foreign or U.S. entity, including partnerships, corporations, and trusts, as well as analyze the income and estate tax implications of these alternatives.
Outline
- Real estate structures for foreign investors: introduction
- Estate tax
- Corporation
- Foreign corporation
- Partnership
- Trust
- Direct investment
- Examples
Benefits
The panel will cover these and other critical issues:
- U.S. income tax consequences of investing in U.S. real estate through a foreign corporation
- Estate tax implications of personal investments in U.S. real estate
- Whether a blocker corporation can negate estate tax
- Utilizing irrevocable trusts to hold U.S. real estate
- Differences in the tax treatment of real estate held by U.S. and foreign corporations
Faculty
Anthony V. Diosdi
Partner
Diosdi & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
Close
Kerrin N.T. Liu
Partner
Diosdi & Liu
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations,... | Read More
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations, domestic tax compliance, and international tax compliance. She has represented clients as second chair in trials before the United States Tax Court. Kerrin also handled Internal Revenue Service, State of California, and FBI criminal investigation cases involving individuals and business entities. In addition, Ms. Liu has assisted clients in a broad range of tax resolution cases.
Close
