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Presentations

Update on FATCA & OVDI

On November 2, 2015, Galia Antebi presented “An Update of F.A.T.C.A.” at the 2015 Advanced Tax Institute, sponsored by the Maryland State Bar Association and the Maryland Association of C.P.A.’s, in Baltimore, Maryland.

The discussion covered an overview of F.A.T.C.A. legislation, the current status of exchanges of financial information between I.G.A. partner countries, and other hot topics, including new account opening procedures in countries that have signed a Model 1 I.G.A.

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Foreign Persons Investing In U.S. Real Estate: Partnership and Other Structures, Opportunities and Traps

Philip R. Hirschfeld presented on the panel “Foreign Persons Investing In U.S. Real Estate: Partnership And Other Structures, Opportunities and Traps” as part of the NYU Advanced Summer Institute in Taxation. The summer institute is offered annually by NYU’s Advanced International Tax Institute. Mr. Hirschfeld’s presentation focused on ways to structure a non-U.S. person’s investment in U.S. real estate in ways that minimize taxation. Investments in mortgage debt securities, partnerships, L.L.C.’s, and R.E.I.T.’s were covered.

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Tax Planning for U.S. persons in Europe – Residency in Europe, Disclosure, Expatriation

Stanley C. Ruchelman and Beate Erwin attended the 2015 ITSG European Conference in Madrid, Spain.

Mr. Ruchelman and Ms. Erwin participated on the panel “Problems of U.S. Person Living in Europe,” which addressed banks that close accounts of U.S. persons, coming into compliance with tax return and F.B.A.R. reports, and planning for expatriation.

In conjuction with the conference, Mr. Ruchelman also spoke on the “Common Reporting Standard in the E.U.”

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ABA Tax Section: FIRPTA, Section 892 and REITS

Form W-8 Workshop

Wealth Planning in the "New Information Age"

Follow Up Work on B.E.P.S. Action 6: Preventing Treaty Abuse

How Much Equity is Enough in a U.S. Entity? When is Debt Treated as Debt?

Double Irish Sandwich: Google Feasts, European Governments Suffer Heartburn

The Life of an Outbound Investment from the U.S. into Canada

Understanding U.S. Taxation of Foreign Investment in Real Property: F.I.R.P.T.A. and Beyond

F.A.T.C.A. and the I.G.A.: How German Businesses, U.S. Citizens, and German Financial Advisors are Affected

U.S. Tax Update: Inversions

A Foreign Grantor Trust is a Great Solution to Benefit U.S. Persons: A Look at How This is Done

Anti-Treaty Shopping: Limitation on Benefits Provisions

International Tax & B.E.P.S.: A Reality Check

Transfer Pricing Today - Where Tax Meets Business Case Study Illustration

Transfer Pricing - The I.P. Paradigm - U.S. Context

Foreign Persons Investing in U.S. Real Estate: Partnerships and Other Structures, Opportunities and Traps