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Bye Bye Brazil – Considerações Tributárias no Planejamento de Investimento Brasileiro dentro dos Estados Unidos - Parte 1

Sou advogado tributário americano. Me formei na academia militar do exército americano em West Point, Nova Iorque. Me graduei em Espanhol e Português. Meus professores eram um tentente coronel do exercito brasileiro formado...more

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part 3 - Inbound Investment Real...

As an undergraduate at West Point, I was a Spanish and Portuguese major. My Brazilian “thing” had already started a decade earlier as a ten year old growing up in the Panama Canal Zone seeing Pele play for his Brazilian team...more

Bye Bye Brazil! - Tax Planning Considerations for Brazilian Investment in the United States: Part II – Additional Income Tax...

I have mentioned in prior articles my affiliation with the South Florida law firm Osborne and Osborne, PA in Boca Raton. Back to the beginning! Boca Raton is where I started right out of the Army in 1987. I moved to Miami for...more

Bye Bye Brazil!- Tax Planning Considerations for Brazilian Investment in the United States: Part I – Income Tax Considerations

Overview - I have mentioned in prior articles that I was a Spanish and Portuguese major as an undergraduate. During the time that I was attending law school at the University of Miami, the early 1990’s, the Brazilians...more

International Tax Compliance Update: Renouncing U.S. Citizenship to Avoid Taxes: Is It Worth It?

As we have reported previously in recent years the United States has intensified its efforts to force United States persons to disclose assets they hold and income they earn abroad. Two prominent examples of these efforts are...more

Analysis: The State of the Union in 2014

INTRODUCTION - On Tuesday, President Barack Obama delivered his fifth State of the Union Address before a joint session of the 113th Congress. In setting forth his priorities for the remainder of the year, he...more

Getting a Green Card Subjects Noncitizens to U.S. Foreign Bank Account Reporting Requirements

A resident or citizen of a country other than the United States who obtains lawful permanent resident status in the United States, often referred to as a “green card,” becomes a resident of the United States for U.S. income...more

Leaving Mainland America Yet Remaining in the United States—Puerto Rican Residency as an Alternative To Expatriation

OVERVIEW - One of the news items that generates political fireworks each year is the number and names of famous Americans who renounce their U.S. citizenship. According to the Wall Street Journal, the United States is...more

Nonresident Alien Spouse Not Liable for Penalties

There are an unknown number of U.S. citizens married to nonresident aliens. Many of these taxpayers have filed joint income tax returns. Most are likely to have filed joint income tax returns (Form 1040) without having...more

Investing In Georgia: Economic Development Newsletter - June 2013

Welcome to King & Spalding's economic development news bulletin, Investing in Georgia. In this edition, you will find: - An economic-impact study linking the use of tax-exempt municipal bonds to the development of our...more

I Want to "Leave" in America - Puerto Rican Residency as an Alternative to Expatriation

Overview - One of the things that generates political fireworks each year is the number and names of famous Americans renouncing their U.S. citizenship. The number is 2012 was about 1800. Regardless of whether you are...more

A Tax Opinion CAn Protect EB-5 VISA Status.

An EB-5 Visa is known as an "investor" visa. The following is an explanation of the EB-5 program...more

EB-5 Visas Applicant Need Tax Opinions

An EB-5 Visa is known as an “investor” visa. The following is an explanation of the EB-5 program...more

Soy Boricua - Rethinking Inbound Tax Planning for Wealthy Latin American Moving to the U.S.

Overview - In case you did not know, Miami is the capital of Latin American. It is the port of entry for Latin Americans from Central and South America. Historically, wealthy Mexicans have liked California and Texas...more

I Want to Live in America!- Part I Tax Planning Considerations for Foreign Scientists and Engineers

Overview - As discussions regarding immigration reform continue to unfold, one point that is not under discussion or subject to debate is the contribution of foreign scientists and engineers to the New Economy. The statistics...more

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 worldwide income. ...more

Congress Returns from Spring Recess

Congress returns to Washington today after a two-week district work period. As we enter the second quarter of the year, we are likely to see continued debate and some progress on: Budget & Appropriations; Presidential...more

Investing In Georgia: Economic Development Newsletter - February 2013

In This Issue: Welcome to King & Spalding's economic development news bulletin,Investing in Georgia. In this edition, you will find: - An overview of the sequester, debt ceilings, continuing resolutions to fund...more

Nonresident Alien Deposit Interest Reporting Requirements Are Now in Effect

Starting January 1, 2013, all commercial banks, savings institutions, credit unions, securities brokerages and insurance companies must report interest on deposits paid to nonresident alien individuals to the IRS and to the...more

The State of the Union in 2013

Introduction - Last night, President Barack Obama delivered his fourth State of the Union Address before a joint session of the 113th Congress. Not since 1887, when President Grover Cleveland faced a divided 50th...more

Tax Traps Accompany EB-5 Visas

EB-5 Visas are sought after investment based pathways to a Green card. An EB-5 Visa is described in Wikipedia as follows...more

FATCA - Dual Nationals, Expatriation or Voluntary Disclosure

Many dual nationals, meaning those U.S. taxpayers who retain citizenship in another country as well as having U.S. permanent residence (Green Card) status or U.S. citizenship, may be considering surrendering their U.S. status...more

Just how is the Expatriation Tax Calculated?

It has been all over the news lately, wealthy U.S. taxpayers, such as, Eduardo Saverin (a Facebook founder), Denise Rich (songwriter), and another eighteen hundred, or so, have forfeited their U.S. citizenship for U.S. tax...more

Strategic Tax Planning for Non-Resident Aliens Using Private Placement Life Insurance- Part III

Part I of this series on investment tax planning for non-resident aliens (NRAs) focused on the potential tax benefits of private placement variable annuities (PPVA). Part II focused on the use of PPVA contracts by NRAs to...more

Non-Citizens Risk Immigration Status for Offshore Bank Accounts

The increased focus by the IRS on foreign income has generated a lot of news and a slew of criminal prosecutions. While US citizens need to consider the possibility of monetary penalties or a long prison sentence, resident...more

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