International Tax Lunch: Choosing a Holding Structure for Investment in U.S. Real Estate by Nonresidents Webcast | 4203819A

Date :
November 13, 2020 12:00 PM - 1:00 PM
Location :
Webcast
Facility :
Webcast Rebroadcast
Level of Difficulty :
Overview
Member Price :
39.00
Nonmember Price :
49.00
CPE Credits :
CPE 1.00, MCLE 1.00, MCLE LS-TX 1.00
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Foreign investors can own U.S. real estate using a variety of holding structures. There is no simple and obviously "best" choice. This session compares taxation of rental income and capital gain, as well as estate and gift tax exposure for a foreign investor. With the 2017 tax law changes, corporations are now much more interesting than they used to be.

 
 

Objectives:

 
  • Identify pros and cons for a variety of real estate holding structures
  • Recognize non-tax related issues for certain holding structures
  • Determine best holding structure based on company activities
 
 

Major Subjects:

 

* Estate tax planning and optimum real estate holding structures
* Capital gain tax planning and holding structure selection
* Taxation of rental income earned by foreign investors
* Branch profits tax, personal holding company tax, and accumulated earnings tax for corporate holding structures

 
 

Advanced Prep:

 

None.

 
 

Misc. Information:

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Level of Difficulty:
Overview
Field of Interest:
Taxes
Prerequisites:
 

None.

 
 
Designed For:
 

Lawyers and CPAs.

 
 

Instructors

Philip D.W. Hodgen, Esq, Esq.
Philip D. W. Hodgen is the principal attorney for HodgenLaw PC, which specializes in the international tax arena. He earned his bachelor’s degree from Claremont McKenna College and his juris doctor degree from the School of Law at the University of California, Los Angeles. He went on to earn a master of laws in taxation from the University of San Diego School of Law. For six years as a youth, he lived in Rhodesia, South Africa and New Zealand. Admitted to the California Bar in 1982, Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. He is a past chair of the International Tax Committee of the State Bar of California’s Tax Section, and was a member of the Executive Committee of the State Bar of California’s Tax Section from 2004-07. He is on the Organizing Committee for CalCPA’s International Tax Conference and its annual Tax Update and Planning Conference. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, bankers, and real estate professionals.

Materials:

  • Materials - ebook