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International Trade Residential Real Estate Tax

Read need-to-know updates, commentary, and analysis on International Trade issues written by leading professionals.

NSW re-opens its door to foreign developers

by Dentons on

The Berejiklian Government has introduced a Bill into the NSW Parliament which may change the way surcharge purchase duty and surcharge land tax applies to foreign developers....more

New GTO covers Wire Transfers

by Foodman CPAs & Advisors on

On August 22, 2017, FinCEN (Financial Crimes Enforcement Network) published a new Advisory regarding Geographic Targeting Orders (GTOs) covering residential real estate transactions in certain counties or boroughs of New...more

Australia Raises Capital Gains Withholding Rate for Foreign Residents in Real Estate Transactions

by Jones Day on

The Australian Commonwealth Government first introduced foreign resident capital gains withholding payments in July 2016 at a rate of 10 percent, in response to issues in collecting tax from foreign resident sellers and...more

Foreign Investor Surcharges Illustrate Lack of Harmonisation in State Tax Policy

by K&L Gates LLP on

In the 17th century the French politician Jean-Baptise Colbert said "the art of taxation consists in so plucking the goose as to procure the largest quantity of feathers with the least possible amount of hissing." For the...more

Forfeiture Case Based on Alleged Elaborate $230 Million Russian Laundering and Fraud Scheme to Settle

by Ballard Spahr LLP on

On the eve of trial this past Friday, the government announced an agreement to settle, subject to court approval, a major civil forfeiture action in the Southern District of New York. In the case, United States v. Prevezon...more

GST & Residential Property: Purchasers to pay GST to ATO

by K&L Gates LLP on

The Government announced in its 2017-18 Budget that, from 1 July 2018, purchasers of new residential premises (new homes / apartments) and subdivided residential lots will need to pay any applicable GST on the sale directly...more

Emmanuel Macron Elected President: French Taxation to Fall in Line with the European Average?

by Dechert LLP on

Following the election of Emmanuel Macron as President of the French Republic, you will find below a few examples of expected tax changes of potential importance to our clients....more

Ontario Introduces 15% Tax on Foreign Real Estate Buyers

by Dickinson Wright on

The Ontario government announced a new proposal to impose a 15 percent tax on purchases of residential real estate by foreign buyers as part of its Fair Housing Plan. Similar to the foreign buyer tax enacted last year by the...more

Update on Domicile and Tax of Offshore Trusts

by McDermott Will & Emery on

Implementation of the 6 April 2017 tax changes applicable to non-domiciled individuals, offshore trusts and UK residential property has been delayed because of the forthcoming UK General Election on 8 June 2017. Whilst it is...more

A Guide to UK Tax on Commercial Real Estate: Non-Residents

by King & Spalding on

1. Introduction - This client alert provides a summary of key UK tax considerations when a nonresident invests into UK commercial real estate. There are a number of holding structures for investment into UK real estate...more

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

by Foodman CPAs & Advisors on

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

Surcharge tax hits discretionary trusts

by Dentons on

The Office of State Revenue (OSR) has released a ruling on 22 December 2016 in relation to the definition a ‘foreign person’. This is important if you hold an investment property in a discretionary trust....more

Final Response to Non-Dom Consultation Published

by McDermott Will & Emery on

The UK government has released its final response to the further consultation on reforms to the taxation of non-UK domiciliaries (non-doms), together with some draft legislation that will take effect from 6 April 2017. As...more

Confirmation of Non Dom Changes in the UK Autumn Statement

by McDermott Will & Emery on

New UK Chancellor Philip Hammond gave his first Autumn Statement on 23 November 2016. Whilst there were no further details relating to the reforms of the taxation of non-UK domiciliaries and UK residential property, the...more

New Regulations Issued Regarding CFCs and Investment in U.S. Property

by Charles (Chuck) Rubin on

Income earned abroad by U.S. controlled foreign corporations can often qualify for deferral of U.S. income tax. If the foreign corporation is a controlled foreign corporation (CFC), its U.S. shareholders may be taxable on...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Using corporate structures to own UK residential property – a dead end?

by Dechert LLP on

Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more

UK Residential Property Tax Reforms Increase IHT Liabilities

by McDermott Will & Emery on

The UK Government has published a consultation document and draft legislation relating to the reforms of UK residential property taxation that are due to take effect from 6 April 2017. The new rules mean that most UK...more

Tax Implications For Real Property Leasing

by Morgan Lewis on

Reforms to China’s value-added tax raise issues that landlords should consider when designing leasing structures and negotiating rental terms. On May 1, 2016, China’s value-added tax (VAT) replaced the business tax in...more

BC imposes additional 15% tax on foreigners effective August 2, 2016

by Dentons on

On July 28, 2016, the BC Government passed legislation to implement changes to the Property Transfer Tax Act. These changes will apply an additional 15% tax on purchases by foreigners of residential property in the Greater...more

Reforms to the Foreign Investment in Real Property Tax Act and REIT Taxation - Tax Update Volume 2016, Issue 1

by Pepper Hamilton LLP on

The reforms generally encourage foreign investment in U.S. real estate. The enacted Protecting Americans from Tax Hikes Act of 2015 (the Act) contains numerous reforms to the Foreign Investment in Real Property Tax Act...more

U.S. Tax Structures Utilized In Connection With Foreign Investment In U.S. Real Estate

by Kelley Drye & Warren LLP on

U.S. real estate is expected to attract a record amount of foreign investment in 2016. The U.S. real estate market is perceived as a safe haven in light of economic uncertainty in China, the refugee crisis in Europe and the...more

"FIRPTA Reform Impacts Investment Opportunities in US Real Estate"

In recent months, much has been written to describe the reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) contained in the Protecting Americans From Tax Hikes Act of 2015 (the Act), which have been...more

Plan Ahead to Avoid or Minimize US Estate Tax

If you are not a US resident or a US citizen and are considering buying assets in the US, there are ways to avoid or minimize US estate tax on those assets. ...more

UK Budget 2016 – Key Tax Measures

The Chancellor of the Exchequer delivered the UK Budget for 2016 on 16 March 2016. The Budget was delivered against the backdrop of international tax developments, relating to the Organisation for Economic Co-operation and...more

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