Virginia La Torre Jeker, J.D. — US tax matters affecting international clients
Part 1 of this blog post introduced readers to some of the issues surrounding US taxation of foreign persons and discussed the pitfalls of tax ignorance. This 2-part series identifies areas of potential US tax exposure for foreign nationals and examines the questions the foreign person and his advisors should be asking before taking a … Continue reading Breathing American Air – Hazardous to your Wealth? (Part II)
Investment decisions are difficult nowadays, but I am still getting inquiries from US persons about the US tax effects of owning foreign real property. Tax efficient structuring depends on numerous factors. While an earlier blog post discussed the general concept of what is called a "disregarded entity" and how it is used (and misused) by … Continue reading Tax Planning – Ownership of Foreign Real Property
Foreign investment in the US real property market is big business. US property sales to foreign buyers in 2019 totaled US$78 billion. A look at statistics from more recent years shows that the largest share of foreign residential investors are from China and Canada, followed by Mexico. The US tax laws apply to foreigners owning … Continue reading IRS Needs Money: NRA’s Owning US Real Estate Will Help the Agency Get it Via Taxes and Penalties
This is a repost with some changes and more research resources to clarify the earlier article. It may be hard to believe, but losing your foreign home to foreclosure can result in US tax consequences. The tax problems are worsened for the American abroad. Today’s post explains why. The topic is becoming more relevant to … Continue reading Woeful American Abroad! Foreign Residence Mortgage? Foreclosure? Debt Forgiveness? Nasty US Tax Surprises Await You
A very important building block when establishing a business is selecting the best type of entity from both a legal and tax perspective. This “choice of entity classification” can make a huge difference in liability protection and tax outcome. When an international business is involved, it should come as no surprise that the complexities only … Continue reading Check-the-Box Election: Is it Really that Simple?
Please pass this along to your friends and colleagues who may have an interest. The International Business and Structuring Association is hosting an event where I, along with other industry leaders, will be covering the unique challenges and opportunities faced by businesses and investors engaged in cross-border transactions between the US and UAE. I hope … Continue reading Business & Investment Structuring Between the USA and UAE
Just last week, the Internal Revenue Service (IRS) reported that it has begun sending letters to taxpayers with virtual currency transactions. The targeted taxpayers are those that potentially failed to report income and pay tax from virtual currency transactions or those who failed to report their transactions properly. Virtual currency transactions involve complex tax issues … Continue reading IRS Hot on the Trail of Virtual Currency Owners: What IRS Letters to Taxpayers Really Mean
Each year, almost 2,000,000 corporations and limited liability companies are being formed under the laws of the various United States. Yet, only a handful of States require information about the beneficial owners of the corporations and limited liability companies formed under their laws. A person forming a corporation or limited liability company within the US … Continue reading No Creation of US Companies or LLCs Without Disclosure! Your Name, Please – Corporate Transparency Act of 2019
Effective as of May 13, taxpayers can no longer request an employer identification number (EIN) unless the "responsible party" named on the application has either a Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN). Only governmental entities and the military are exempt from this requirement, and may continue to list non-individual entities as … Continue reading Head’s Up! IRS Just Revised EIN Application Procedure & Foreign Taxpayers Will Struggle
I work frequently with married couples of mixed nationality, when one spouse is not a US citizen and the other has such citizenship. Without due consideration to the US tax issues, spouses often hold title to bank accounts, brokerage accounts and real property as joint tenants with right of survivorship. Joint ownership often comes about even … Continue reading A Big Mistake – Joint Ownership of Assets With Your Non-US Citizen Spouse
Virginia - US TAX TALK 