Dispositions of U.S. real property interests by foreign partners - tax provisions, pitfalls, and planning possibilities

Article Abstract:

US real estate investors considering joint ventures with foreign investors should be aware of how to minimize taxation of joint ownership. Low US real estate prices and tax rates and the favorable exchange rate are encouraging foreign investors to back US developers. However, the Foreign Investment in Real Property Tax Act of 1980 requires foreign owners to pay a tax on gains from the sale of property and sets reporting requirements. Nonresident aliens and their US partners should use the partnership form of the passthrough tax treatment as tax-reducing investment device.

Laws, regulations and rules, Real estate, Joint ventures, Real property

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Foreign investors reshuffle the deck

Article Abstract:

Foreign investors can safely invest in US real estate despite adverse local and international economic conditions. The Japanese will invest at a decreased rate and will restructure existing investments. Hong Kong and Taiwanese investors will consider the US market to buffer the projected losses resulting from the Chinese takeover of Hong Kong in 1997. The Europeans will take advantage of the real estate bargains. Foreign real estate infusion will concentrate on low-profile investments and the restructure previous investments.

Evaluation

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The new holding company regime - the best of both worlds

Article Abstract:

Favourable taxation laws in Denmark are expected to result in many firms establishing a holding firm registered in Denmark to take advantage of low tax rates for share-owned subsidiaries. The auditing requirements means all company accounts must be prepared in Denmark, although foreign firms will be able to overcome this issue. The only restriction governing the sale of subsidiary share tax exemption is a three-year share ownership time scale, which is more prohibitive than other European countries.

Tax Law, Public Finance Activities, Corporate Tax Deductions & Exemptions, Denmark, Finance, Corporate taxes, Holding companies

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