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Blame It on the Bossa Nova! A One Note Samba for Inbound Real Estate in the U.S

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

Taxing Non-Residents on Capital Gains from UK Residential Property – UK Government Consults on New Rules

The UK does not generally impose tax on capital gains of non-UK residents in relation to real estate properties in the UK. However, the Government has announced that tax will be imposed on future capital gains made by non-UK...more

U.S. and European Cross-Border Real Estate Investment: Key Structuring Considerations

Deploying real estate capital across international markets can be a complex exercise, and structuring cross-border investments so that capital can be brought back efficiently adds to the complexity. Accommodating the...more

2014 U.K. Budget: Impact on Alternative Asset Managers

Chancellor George Osborne delivered his fifth coalition Budget today. In a wide-ranging statement, there are a significant number of tax-focused proposals that will make changes across the U.K. tax system. Some of these...more

Japan Back In Spotlight For Real Estate Investment

Japan is back in the spotlight for international real estate investors. Recent surveys indicate that Japan was the third most active market globally in 2013 after the U.S. and the U.K., with transaction volumes of...more

Minimizing Estate Tax On U.S. Real Property

Canadians’ interest in acquiring U.S. real property for personal use remains strong. Without proper planning, however, that acquisition will expose the Canadian purchaser to U.S. estate tax on the fair market value of the...more

Real Estate Capital Gains Tax for Non-U.K. Residents

From April 2015, nonresidents will have to pay capital gains tax (CGT) on gains made from residential property sales in the United Kingdom, George Osborne announced today....more

The Portfolio Interest Exemption: A Pretty Good Thing

You know what’s better than earning portfolio interest? Nothing. OK, that may be an overstatement. But for non-U.S. lenders looking to earn a return on their U.S.-based investments, with respect to paying U.S. taxes, that’s...more

Capital Gains Tax on U.K. Property for Non-Residents

According to various reports, the Chancellor of the Exchequer is considering announcing in his Autumn Statement in December that capital gains tax (“CGT”) will be imposed on non-U.K. resident property sellers for the first...more

Comprehensive Tax Reform Remains a Top Priority for Key Members

Congressional Consideration Continues, Including Provisions That Would Impact the Real Estate Industry - The House Ways & Means Committee is currently holding Member-level discussions on tax reform and is in the...more

Foreign Investors In REITs: Opportunities Under FIRPTA Reform Proposals

Real estate investment trusts (REITs) have long been a tax-efficient vehicle for foreign persons seeking to invest in U.S. real estate. Now, two legislative proposals titled the Real Estate Investment and Jobs Act of 20131...more

Proposed FIRPTA Changes Would Attract More Foreign Investment In U.S. Real Estate

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 U.S. Real Property Tax...more

Let’s Make a Deal! Is there a Better Way to Structure U.S. Private Equity and Real Fund Investments for Foreign Investors?

Overview - Sophisticated tax structuring is generally involved in the investment activities of foreign private and sovereign investors in U.S. private equity and real estate investments that generate effectively...more

House Bill Proposes Narrowing Scope Of Firpta; Eases Burdens On Reits

A bill introduced late last month in the United States House of Representatives (H.R. 2870) by Congressmen Kevin Brady, a Republican from Texas, and Joseph Crowley, a Democrat from New York, sets forth several proposed...more

"New FIRPTA Reform Would Attract Foreign Investment in US REITs"

Yesterday, Reps. Kevin Brady of Texas and Joseph Crowley of New York proposed a major reform to the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R. 2870, the Real Estate Investment and Jobs Act of...more

International Tax News - June 2013

In This Issue: New tax treaty boosts Netherlands for inbound Chinese investment; Germany: far-reaching compromise proposed re Tax Act 2013; and, Italy clarifies tax laws re air carriers. ...more

Ropes & Gray’s Private Investment Fund Update: June 2013

Highlights - SEC Updates Form PF "Frequently Asked Questions" - The SEC recently released updated "Frequently Asked Questions" relating to Form PF that, among other things, clarified how Form PF filers should...more

Internal Revenue Service Concludes that Fideicomiso or Mexican Land Trusts are not "Trusts" for United States Tax Purposes

On June 6, 2013, the Internal Revenue Service issued Revenue Ruling 2013-14, which concludes that a Fideicomiso or a Mexican Land Trust (MLT) is not taxed as a “trust” for U.S. income tax purposes. While most practitioners...more

Spike In Real Estate Creates Tax Planning Opportunities For South Florida Property Owners

Although it may come as a surprise to many, it is no secret that South Florida property values are on the rise. ...more

Tax Reform Update: Impact on Private Equity, Hedge Funds, and Real Estate Partnerships

Interesting tax update courtesy of Bruce Thompson, a Senior Policy Advisor with DLA Piper. He continues to see momentum for comprehensive tax reform and wrote the following summary of what that might mean for fund managers...more

IRS Rules that Mexican Fideicomisos or Land Trusts are not Trusts for U.S. Tax Purposes

On June 6, 2013, the IRS released Revenue Ruling 2013-14, which holds that Mexican fideicomisos or Land Trusts are not trusts for U.S. tax purposes. “Fideicomisos have been an issue in the offshore disclosure world for quite...more

Investing in luxury properties in France: a counterflow strategy that could pay off

Since the new taxation reform was passed earlier this year, a number of wealthy owners have moved out of France and put up their properties for sale. This resulted in an exceptional price fall of up to 15% for properties over...more

Considerations For International Clients Who Intend to Buy A Home In the U.S.

International buyers invested $82.5 billion in U.S. residential real estate (4.8% of total U.S. sales) according to the most recent survey conducted by the National Association of Realtors for the 12 month period ending with...more

Third Circuit Court of Appeals Issues Landmark Decision in Virgin Islands Economic Development Program Case

Disclosure: Joseph A. DiRuzzo, III of Fuerst Ittleman David & Joseph was part of the trial team that represented the taxpayers in the June 2010 bench trial in the District Court of the Virgin Islands....more

Financial Services – Update on UK and European Regulatory Developments - March 2013

In This Issue: - Part A – Regulation of Financial Markets - Part B – Regulation of Investment Management - Part C – Regulation of Investment Funds - Appendix: Regulatory Calendar – Key Milestones Please...more

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