Tag: FIRPTA

  • Offshore Tax Planning for Project Financing

    [box size=”large” style=”rounded”]Historic structures: transfer pricing, diverted profit tax, carried interest no longer function for offshore tax planning.[/box] [box type=”alert” size=”large” style=”rounded”]Investment vehicles require a look at what the future is to be.[/box] [box type=”info” style=”rounded”]Governments and governance look through everything. Everything is considered a tax avoidance scheme except that which is formally recognized and…

  • Miami Real Estate and the Panama Papers

    Miami Real Estate Expert Ross Milroy explains why creating shell companies is no “Game” and vital to the very people who sparked Miami’s resurgence MIAMI – In light of the recent Panama Papers leak, offshore shell companies are receiving unprecedented attention, and more often than not, portrayed as this years Ponzi scheme. Real estate and…

  • The Trend in Chinese Offshore Investment

    The trend in Chinese offshore investment in the U.S. has been increasing each year. In 2012 the level of investment was $6.5 billion. Much of this investment is in U.S. real estate where great buying opportunities still exist. The registered foreign retirement plan is an ideal asset protection vehicle for Chinese investors that make investments that…

  • Bye Bye Brazil! – Tax Planning Considerations for Brazilian Investment in the United States: Part II – Additional Income Tax Considerations

    I have mentioned in prior articles my affiliation with the South Florida law firm Osborne and Osborne, PA in Boca Raton. Back to the beginning! Boca Raton is where I started right out of the Army in 1987. I moved to Miami for law school. Even though I have been living in New England and…