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US real estate miniseries #1 – direct ownership
Hi, it’s Phil Hodgen again. Welcome to the Friday Edition. If you want to stop getting this thing every Friday, just click the “unsubscribe” link at the bottom of this email. I won’t be offended. On...
View ArticleUS real estate miniseries #2 – direct foreign corporation ownership
Hi, it’s Phil Hodgen again. Welcome to the Friday Edition. If you want to stop getting this thing every Friday, just click the “unsubscribe” link at the bottom of this email. I won’t be offended. On...
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US real estate miniseries #3 – foreign parent, domestic subsidiary
Hi, it’s Phil Hodgen again. Welcome to the Friday Edition. If you want to stop getting this thing every Friday, just click the “unsubscribe” link at the bottom of this email. I won’t be offended. On...
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US real estate miniseries #4 – foreign corporation plus income tax treaty
Hi, it’s Phil Hodgen again. Welcome again to the Friday Edition. This episode is written from seat 3E on American Airlines flight 126 — LAX to Chicago. Wifi in the sky for the win, right? (Also: Bose...
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How Should I Own My U.S. Real Estate?
How I Think About Real Estate Holding Structures Foreign investors in U.S. real estate always have the same question: How should I own the real estate that I am buying in the United States? This is how...
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Withholding when Nonresidents Own U.S. Rental Real Estate
Proving the Obvious In a quick email exchange I had with Susan Brown Otto (hi Susan) we touched on a topic that deserves attention. The topic is not terribly difficult, but its existence points to a...
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Nonresident Investor in U.S. Real Estate: Impossible Structures
This is the beginning of a new series. It’s a “nonresident investor in U.S. real estate” series. I’m going to analyze a simple (!) client question: “I am a nonresident of the United States. I am going...
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Real Estate Holding Structures Guaranteed to Cause Estate Tax
We continue in the series about holding structures for nonresidents who buy U.S. real estate. In the last episode . . . In the first episode, I showed that there are 13 types of single-level holding...
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Real Estate Holding Structures: “Maybe” Means “No”
The “Real Estate Holding Structure” Series This is the third episode of the real estate holding structure series. In this series I walk you through the thought process of a non-resident who wants to...
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Real Estate Holding Structures: Single-Tier Structures With No Estate Tax Risk
The “Real Estate Holding Structure” Series This is the fourth episode of the real estate holding structure series. In this series I walk you through the thought process of a non-resident who wants to...
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