|We are pleased to announce that Jack will be speaking in the upcoming GRC Educators live webinar, “FIRPTA Tax Planning And Compliance After Tax Reform” scheduled for Monday, April 22, 2019 at 12:00pm EST.
The program will provide participants with the U.S. federal income, estate, and gift tax implications and planning techniques to properly advise their foreign investor clients on how to best structure their U.S. real property investments under the new tax rules of the Tax Cuts and Jobs Act.
Advising foreign real property investors requires tax and other professionals involved with foreign real property investors to understand the U.S. tax reporting and withholding requirements to best advice their clients and provide investment structuring options.
The new tax law did not change the existing liability and withholding requirements on the disposition of U.S. real property interests but did affect change in possible FIRPTA investment structures because of the lowered withholding tax rate on capital gains and liquidating distributions paid by REITs. There are additional Net Operating Loss and interest expense limitation rules as well as depreciation rule changes under the new tax law. Also, the use of a blocker corporation may likely be subject to Base Erosion Tax (BEAT) on interest payments made to or accrued by blocker corporations to its related foreign lender.
Additionally, participants will be exposed to the use of offshore common law and civil law wealth transfer structures to invest in U.S. real property and the U.S. tax implications and reporting requirements of said structures investing in U.S. real property.
· Overview of tax rules that apply to foreign investors in U.S. real estate
· U.S. income, estate, and gift tax
· Income tax residency and estate and gift tax residency rules
· FIRPTA and withholding requirements
· Treaty application
· A typical structure of blocker corporation for foreign persons or corporations to hold U.S. real property assets
· Changes in TCJA tax reform that will specifically impact income from owning or disposing of U.S. real property
· Corporate rate reduction and FIRPTA withholding rates
· Treatment of REITs
· Base Erosion and Anti-Abuse Tax (BEAT)
· Depreciation changes
· New NOL carryforward rules
· Planning opportunities through entity selection or change
After the presentation, there will be a live question and answer session.
We do hope you will join us. Form more information or to register:
Or call (704) 870-0321 / +00 1 704 870 0321
Ask for FIRPTA Tax Planning And Compliance After Tax Reform on 22-Apr-2019