Changing Investment Structures for Foreign-Owned US Real Property has Many Traps for the Unwary
June 8, 2015
International Tax
There are various ways to structure a foreign investment in US real property and each has its own advantages and disadvantages (see below for a link to a previous blog post on this topic). A frequently chosen structure is a pass-through or fiscally transparent structure which, very generally, has income tax…
Real Estate Investor Forced to Recognize Ordinary Business Income Instead of Capital Gain, Despite Holding Property Without Physical Improvement For Over a Decade
June 1, 2015
Capital Gain Transactions
Sometimes it’s what you say, not what you do, that matters. A taxpayer learned that the hard way in a recent United States Tax Court decision. There are numerous court decisions in which a taxpayer acquired property, incurred “soft costs” to entitle the property for future development, and then recognized capital gain…
Can Your Estate Plan Become More Effective if You Use an Holistic Approach Unique to Your Own Family’s Goals?
May 26, 2015
Estate Tax
Estate Planning is hard for many reasons—from discomfort with death to difficult family dynamics. It is made harder by complicated tax laws and documents. Too often, in estate planning, the focus is solely on tax planning without considering the impact of the planning upon the family or incentivizing the type of…
The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of-money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for June 2015: Short Term AFR…