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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. […]

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Trump’s Tax Plans

November 10, 2016

Donald Trump’s surprise election win has people wondering about his tax plans. Many things said on the campaign trail never result in any change. To achieve any of his tax plans, Trump will need the cooperation of Congress, including those he likely alienated, if not excoriated during the campaign. Trump has made the common but […]

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US Tax vs. Canadian Tax

December 3, 2012

There are many similarities between the U.S. and Canada, but there are some significant distinctions between U.S. and Canadian tax law especially for U.S. citizens resident in Canada, including permanent residents of the US (“green-card” holders). For the unwary those distinctions may result in substantial U.S. tax liabilities where those differences are not identified in […]

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US Persons Holding Non-U.S. Mutual Funds

November 20, 2012

U.S. citizens and lawful permanent residents (green card holders) who hold certain investments may unknowingly be subject to adverse US tax implications where the investments are characterized as investments in Passive Foreign Investment Companies (“PFICs”). PFICs include non-U.S. mutual funds and exchange traded funds (ETFs) which are typically organized as corporations or trusts in Canada. […]

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