Jeffrey DeBoer on the intersection of Washington and commercial real estate
The IRS has finally taken a view on the exception to FIRPTA (the Foreign Investment in Real Property Tax Act) for publicly traded stock of a United States real property holding corporation (a “USRPHC”) that is held by a...more
The US Department of Treasury recently released final regulations providing guidance on the exception from taxation under the Foreign Investment in Real Property Tax Act of 1980 for “qualified foreign pension funds” under...more
Hedge Funds and Taxes - Hedge funds provide a vehicle to pool private capital for investment in stocks, securities and financial derivatives. While hedge funds take on many different structures—including master-feeder,...more
Effectively Connected Income - Unlike FDAP income, the United States taxes effectively connected income (“ECI”) on a net basis. Effectively connected income is income that is effectively connected with the conduct of a U.S....more
The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income. A foreign taxpayer’s U.S.-source income falls into one of two general categories: (i) “fixed or determinable annual...more
Convertible debt is exceptionally attractive to investors in volatile markets because it offers the security of a bond with the upside of equity. That is why convertible debt was one of the strongest asset classes during the...more
Divorce is not a topic most clients or tax advisors enjoy discussing. Nevertheless, it is important in today's day and age to advise clients, especially high-net-worth individuals with substantial assets located in the U.S....more
On 9/14/20, the IRS announced 4 New Compliance Campaigns . One Campaign addresses FIRPTA (Foreign Investment in Real Property Tax Act of 1980) Reporting Compliance for Non-Resident Aliens (NRAs). FIRPTA authorized the United...more
Este artículo relacionará los beneficios del uso de fideicomisos estadounidenses para ciertas inversiones entrantes. Fideicomisos de EE. UU., considerados fideicomisos extranjeros con fines fiscales, es una nota....more
This article is will tie together the benefits of using U.S. trusts for certain inbound investments. U.S. trusts deemed to be foreign trusts for tax purposes (is one note). ...more
The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more