This update is meant to provide U.S. investors in real estate with information regarding a federal tax election that may ease the federal income tax burden of income created by debt forgiveness, including any reductions in...more
Bilzin Sumberg is pleased to share the results of the 2019 South Florida Opportunity Zone Survey and subsequent Forum that we co-hosted with Urban Land Institute Southeast Florida/Caribbean (ULI SE FL/Caribbean) on June 5,...more
One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more
Converting Subpart F Income into Qualified Dividends -
U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more
6/13/2014
/ Controlled Foreign Corporations ,
Corporate Conversions ,
Dividends ,
Foreign Corporations ,
Foreign Investment ,
Jurisdiction ,
Repatriation ,
Shareholders ,
Subpart F ,
Tax Planning ,
Tax Treaty
The privatization of the space industry has seen dramatic growth in recent years, and it appears that more significant developments are on the horizon....more
5/29/2014
/ Aerospace ,
CFC ,
Foreign Tax ,
Income Taxes ,
NASA ,
Passive Activity ,
Privatization ,
SpaceX ,
Tax Credits ,
Tax Planning ,
Tax Rates
The Internal Revenue Service has announced that same sex couples legally married in a state whose laws authorize such a marriage will be deemed to be married for Federal tax purposes, even if they live in a state (such as...more
It is no secret that the South Florida real estate market has been a buying opportunity for wealthy foreigners, in light of the decline in U.S. home prices and the lower value of the U.S. dollar against some foreign...more
Although it may come as a surprise to many, it is no secret that South Florida property values are on the rise. ...more
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 worldwide income. ...more
With a new year comes a new beginning. While New Year’s Day is typically viewed as a chance to start fresh and make changes in our personal lives, for many people New Year’s Day in 2013 took a different tone. Instead of...more