Pre Immigration Income Tax Planning

Substantial Presence Test

Richard S. Lehman Esq. is posting frequently asked questions recently received on the topic: Tax planning techniques for the foreign real estate investor. Question 1: What unique tax applies to foreign corporations that does not apply to any other Taxpayers?

Posted in Pre-immigration income tax planning, United States Taxation of Foreign Investors

This article has been translated into French - it is a general overview of United States Taxation of Foreign Investors

Système d’Imposition des Investisseurs Etrangers aux Etats-Unis Système d’Imposition Américaine des Sociétés Etrangères et des Etrangers Non Résidents Règles Générales Planning Fiscal Avant d’Immigrer aux Etats-Unis Planning Fiscal pour l’Investisseur Etranger de Biens Immobiliers INTRODUCTION Pendant de nombreuses années, les

Posted in Pre-immigration income tax planning, United States Taxation of Foreign Investors Tagged with:

The FATCA Team Approach; The Role of Lawyer and Accountant

FATCA and the Team approach

There are several new laws in place to implement the reporting of these foreign bank accounts and to permit U.S. taxpayers to “clear the record” in the event they have not reported these accounts in the past.

Posted in Domestic Taxation, IRS Amnesty, OVDP, Bank Deposits, Foreign Assets, Streamlined Compliance, Settling with the IRS Tagged with:

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.

Posted in Foreign Investors in United States Real Estate, United States Taxation of Foreign Investors Tagged with: , , ,

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)

Posted in Foreign Investors in United States Real Estate, United States Taxation of Foreign Investors Tagged with: , , , , , ,

IC-DISC and United States Exporting of Computer Software, Internet Sales and Licenses

Export Property

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”.

Posted in Exporting Tax Benefits The IC-DISC Tagged with: , , , , , , , , , , , , ,

The New IRS Streamlined Filing Compliance Procedures

Here are frequently asked questions about the IRS changes to the Offshore Bank and Foreign Asset Disclosure Programs. Question 1. Will a taxpayer qualify for either of the Streamline Program or the Offshore Voluntary Disclosure Program that permits Taxpayers to

Posted in Domestic Taxation, IRS Amnesty, OVDP, Bank Deposits, Foreign Assets, Streamlined Compliance, Settling with the IRS Tagged with: ,

A General Overview to Foreign Investing in United States Real Estate

Investing in United State Real Estate- General Overview By Richard S. Lehman, Esq Total presentation time: 67:07 Tax planning for the non-resident alien individual and foreign corporate investor that is planning to invest in United States real estate. These are

Posted in Foreign Investors in United States Real Estate, Pre-immigration income tax planning Tagged with: , ,
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Richard S. Lehman, Attorney At Law

Attorney Profile“The best rule to follow in the field of tax law is to plan legal matters and obtain precision advice in advance to insure commercial endeavors are completed at minimum tax costs and personal lives are minimally disrupted.” - Richard S. Lehman, Esq.

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