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Is the interest expense deductible for US non-resident aliens owning a US real property interest?

Loaning between business entities is a widely-adopted business strategy in the real estate industry. Multiple levels of entities are often chosen in a business structure.

U.S. limited liability companies (“LLC”) are commonly used to hold U.S. real property interests. When foreign investors are involved for various reasons (i.e., asset protection), foreign investors use a non-U.S. corporation that is treated as a disregarded entity for U.S. federal income tax purposes to be the sole owner of the U.S. LLC.

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Canadian Tax – Federal Liberal Tax Changes on Private Corporations

September 22 2017

Over the last few months, much has been written about the proposed Canadian tax changes to private corporations. I am concerned about the speed at which the Department of Finance is moving to enact these significant and wide reaching tax changes.  The proposals were introduced in the summer, while Parliament was not in session, and sought out feedback during a short 75 day window while many Canadians were on holidays and other hard working farmers were busy harvesting.  My concern is that such complex tax matters need further review, study and consultation else they will have a significant impact on our economy. Some of the better commentary on these proposed tax changes that I have read this summer is in thelinks below:

Canadian Tax Law

Trump’s Tax Plans

November 10 2016

Donald Trump’s surprise election win has people wondering about his tax plans. Many things said on the campaign trail never result in any change.  To achieve any of his tax plans, Trump will need the cooperation of Congress, including those he likely alienated, if not excoriated during the campaign.

US Tax Law

Update on IRS Tax Amnesty Programs

February 5 2016

For the last eight years, the Internal Revenue Service has offered a number of tax amnesty programs to allow taxpayers to come forward and declare unreported non-US source income and assets.  Using these programs reduces penalties and can prevent criminal prosecution. 

Amnesty Programs, Streamlined Filing Procedure, US Citizens Resident In Canada