Home Thoughts from Abroad: When Foreigners Purchase U.S
HOME THOUGHTS FROM ABROAD: WHEN FOREIGNERS PURCHASE U.S. HOMES Authors PROLOGUE Stanley C. Ruchelman Michael J.A. Karlin Your real estate partner comes into your office, saying: Tags We have a new client, Mr. N.R.A., who is buying the most expensive 897 house in town. Here is what he wants to do: not buy it in his own 1445 name; not pay rent; allow his wife and children (some of whom are Estate Tax U.S. residents) to use the house; not pay estate tax, should he die; F.I.R.P.T.A. Withholding not pay gift tax, should he give it away; not file a tax return; and not Gift Tax pay tax when he sells the property. Nonresident “No sweat,” I told him. “We can do it; my tax partner is the smartest planner in town.” Real Estate Structure Planning Is it doable? Does our quiver hold enough tax planning arrows to meet all those Transparency goals? U.S.R.P.I. U.S.R.PH.C. INTRODUCTION This report is concerned with a seemingly simple subject: how to plan the acquisition, ownership, and disposition — by sale, exchange, gift, or bequest — of residential real property in the United States for a nonresident alien client.1 For many Americans, as we are regularly reminded, the purchase of a home is the single largest financial transaction of our lives and, because it is the policy of the federal and state governments to encourage homeownership, this investment ben- This article was originally efits from extraordinary tax advantages.
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