This article describes the basic U.S. federal income tax payment obligations that apply to the income and gains from investment by foreign investors who are non-U.S. residents in private investment funds that invest in U.S. real property. These obligations will impact the total financial return on investment of investors, and in some cases will require […]
Scott Harshman’s article “Tax Alert: Foreign Entity Ownership Compliance – Don’t Ignore the Repatriation Tax” was republished by Hospitality Trends on January 28th, 2019.
Jim Butler and Scott Harshman posted “Tax Alert: Foreign Entity Ownership Compliance – Don’t Ignore the Repatriation Tax,” on the Hotel Law Blog on January 23rd, 2019.
In 2017, if a client owned an interest in a foreign entity (directly or indirectly through a tiered entity structure), then an evaluation should have been done to determine whether the client owed a repatriation tax under the Tax Cuts and Jobs Act (TCJA). Many clients, and their tax advisors, are unaware of this obligation […]
Foreign individuals who intend to permanently reside in the U.S., or do not intend to reside in the U.S. but intend to own U.S. property, need considerable legal and tax planning. The definition of “U.S. property” for international tax purposes is a term of art and complex. This planning should be done in advance to […]
Executive Summary The Obama Administration released its proposed budget for fiscal year 2014 on April 10, which included several proposals affecting estate planning. These are described in the Treasury Department’s General Explanations of the Administration’s Fiscal Year 2014 Revenue Proposals (commonly referred to as “the Greenbook”). Noticeable by its absence was the perennial proposal to […]
Gordon Schaller and Scott Harshman’s article, “Why Last Chance Estate Planning May End Soon” was reprinted by Steve Leimberg’s Estate Planning Newsletter, March 2012.
"Last Chance" Estate Planning May End SoonThis article was first published in the Orange County Business Journal, February 13, 2012 Much has been written about the perfect storm of estate planning: the coincidence of low values, low interest rates, valuation discounts and the $5 million ($10 million for a married couple) gift and estate tax […]
To almost everyone’s surprise, new legislation for estate and gift tax laws went into effect in 2011 that increased an individual’s exemption to $5 million ($10 million for a married couple) for both estate tax and gift tax purposes and reduced the estate and gift tax rate to 35%. Unfortunately, these new laws are only […]
Gordon Schaller and Scott Harshman authored Chapter 1 of the California CEB Special Needs Trust Book titled "Introduction to Planning for Persons With Disabilities."