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Tax Structuring of Foreign Investment in South Florida Real Estate
Foreign Investment In South Florida Real Estate Heats Up According to a recent report, international buyers are driving sales at several large real estate projects in South Florida. The 200-unit Trump...
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Florida Residency Required for Homestead Protection
One of the top reasons for moving to Florida, aside from the year-round sunny weather and the multitude of exciting things to do, is the homestead protection afforded to Florida residents. Article X,...
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Will The IRS Report Non-U.S. Taxpayers’ Bank Deposit Interest To Foreign...
Banks’ Reporting Requirements Raise Privacy Concerns Effective January 1, 2013, U.S. financial institutions will be required to annually report bank deposit interest earned by non-U.S. residents to the...
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Unique Provisions in New U.S.-Chile Income Tax Treaty Should Lead to...
Income Tax Treaty Only Third Signed with Latin American Jurisdiction Since the U.S.-Chile Free Trade Agreement came into force in 2004, bilateral trade between these two countries has more than...
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Some Dividends Received from Cypriot Corporations not Eligible for Qualified...
When Is a Statutory Benefit a ‘Treaty Benefit’? When the IRS Says So! Since Section 1(h)(11) was enacted as part of the Jobs and Growth Tax Relief Reconciliation Act of 2003, questions have been raised...
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Shared Appreciation Mortgages Key For Foreign Investors
The combination of a weak U.S. dollar and low interest rates has resulted in more foreign investment in U.S., and South Florida, commercial real estate. But one of the primary obstacles facing foreign...
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Expatriation Lite: Leaving the U.S. Tax System While Retaining Your Citizenship
As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their...
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Proposed FIRPTA Changes Would Attract More Foreign Investment in U.S. Real...
Non-U.S. taxpayers are generally exempt from U.S. federal income tax on gain from the sale of U.S.-situs capital assets. The one major exception is U.S. real estate. Under the Foreign Investment in...
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Tax Planning for U.S. Companies with Latin American Operations
Pass-through structures Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries. With...
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