Bilzin Sumberg - International Taxation

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Miami, Florida 33131-3456, United States

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How Windstream Ruling Will Affect Foreign Taxpayers

In general, a REIT is a special purpose entity for U.S. federal income tax purposes that requires at least 75 percent of the value of the entity’s gross assets to consist of real estate assets, cash, cash items, and governmental…more
| Commercial Law & Contracts, International Law & Trade, Securities Law, Taxation, Real Estate - Commercial

IC-DISC Benefits Enhanced with Foreign Shareholders

Since the reduction in the individual tax rate on qualified dividends in 2004, the Interest Charge Domestic Sales Corporation (“IC-DISC”) has become an attractive vehicle to obtain a tax incentive for exporting U.S.-produced…more
| Business Organizations, Commercial Law & Contracts, International Law & Trade, Taxation

Local Law Shopping Through “Derivative Benefits”

Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on two categories of income: (i) certain types of passive U.S.-source income (e.g.,…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

Inbound U.S. Tax Planning With Inversions

With all of the recent negative publicity focused on the outbound restructuring of U.S. multinationals engaging in so-called “inversion” transactions (see prior blog “Corporate Inversions Showing No Signs of Slowing Down”),…more
| Business Organizations, Commercial Law & Contracts, International Law & Trade, Taxation

Synthetic Investment in U.S. Real Estate by Foreign Investors

According to recent reports, foreign investment in commercial U.S. real estate exceeded $38.7 billion in 2013 - a 40 percent increase over 2012. Leading the way in 2013 were investors from Canada, China, Australia, Germany, and…more
| Finance & Banking, International Law & Trade, Taxation, Real Estate - Commercial

Check-the-Box Elections: Relevance in the International Context

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
| Business Organizations, Commercial Law & Contracts, Immigration Law, International Law & Trade, Taxation

Affirmative Use of U.S. Partnerships in Inbound Tax Planning

A “U.S. shareholder” of a controlled foreign corporation (CFC) is required to include in its gross income its pro rata share of a CFC’s “subpart F” income, regardless of whether such income is distributed. In general, a CFC is…more
| Commercial Law & Contracts, International Law & Trade, Securities Law, Taxation

Corporate Inversions Showing No Signs of Slowing Down

In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or transfers…more
| Elections & Politics, Mergers & Acquisitions, International Law & Trade, Science, Computers, & Technology, Taxation

Retroactive Tax Planning

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
| Business Organizations, Commercial Law & Contracts, International Law & Trade, Securities Law, Taxation

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)…more
| Bankruptcy, Business Organizations, International Law & Trade, Securities Law, Taxation

Tax Planning for the Privatization of the Space Industry

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
| Finance & Banking, Science, Computers, & Technology, Taxation

Determining Foreigners Insolvency Exception

Can a foreign person exclude foreign-situs assets in determining insolvency exception to cancellation of indebtedness income? With the worldwide global default rate on corporate debt continuing to rise, a taxpayer’s…more
| Bankruptcy, Commercial Law & Contracts, International Law & Trade, Taxation

The High-Tax Exception And Malta’s Refund System

A Match Made in Heaven - U.S. shareholders of foreign corporations are generally not subject to U.S. federal income tax on the earnings of such corporations until those earnings are repatriated to the shareholders in the…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law, Taxation

Foreign Investment In The U.S. Through Romania Just Became More Interesting

All “modern” income tax treaties concluded by the United States contain a “Limitation on Benefits” (LOB) provision. The purpose of such a provision is to prevent “treaty shopping.” Romania is one of the few remaining countries…more
| Finance & Banking, International Law & Trade, Taxation
Areas of Practice
  • International Law & Trade
  • Taxation
Locations
Other U.S. Locations
  • Florida
Number of Attorneys

100+ Attorneys

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