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Is the interest expense deductible for US non-resident aliens owning a U.S. real property interest?
Loaning between business entities is a widely-adopted business strategy in the real estate industry. Multiple levels of entities are often chosen in a business structure. U.S. limited liability companies (“LLC”) are commonly used to hold U.S. real property interests. When foreign investors are involved for various reasons (i.e., asset protection), foreign investors use a non-U.S. […]
Outbound Issues – Ownership of Non-U.S. Corporations Subpart F Income
October 17, 20173 Day Tax Conference November 15 – 17, 2017 – Burbank, CA Join Steven Flynn, a partner with W.L. Dueck & Co. LLP at an upcoming CalCPA Tax Conference in Burbank, Los Angeles on November 15 – 17. During this Federal, State, Local & International Taxation Conference, Steven will bring expertise on Outbound Issues, Ownership […]
Tax Planning Using Private Corporations – July 18, 2017 Paper (“Paper”) Request for Comments
October 2, 2017Department of Finance Canada Via email: fin.consultation.fin@canada.ca RE: Tax Planning Using Private Corporations – July 18, 2017 Paper (“Paper”) Request for Comments Dear Recipients: We have read the Paper, reviewed many articles and discussed with and listened to our clients, colleagues and others in our community. We have concerns with the proposed changes in their […]
Canadian Tax – Federal Liberal Tax Changes on Private Corporations
September 22, 2017Over the last few months, much has been written about the proposed Canadian tax changes to private corporations. I am concerned about the speed at which the Department of Finance is moving to enact these significant and wide reaching tax changes. The proposals were introduced in the summer, while Parliament was not in session, and […]
