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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, August 29, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This webinar will discuss how a leveraged blocker corporation can maximize net returns to non-U.S. investors and minimize U.S. reporting requirements. Our panel of global structuring experts will review the benefits of leveraged blockers, calculating the tax benefits, and alternative structures that international tax advisers should sometimes consider.

Faculty

Jay Freedman
Principal
KPMG Law, LLP

Mr. Freedman is a Principal in KPMG’s Financial Services Tax Practice, and serves as the firm’s Global Industry Leader for the firm’s Hedge Fund Tax Practice.  For over 30 years, he has focused on a broad array of tax issues, across financial products and derivatives, cross-border structuring and transactions, partnership tax, and corporate tax, with an emphasis on issues related to the alternative investment and banking industries. Mr. Freedman has significant experience in both tax consulting and tax compliance and regularly advises clients on tax planning for structuring funds and portfolios. He offers clients an experienced perspective, having served in several senior-level in-house positions at major organizations in the international investment manager, securities dealer, and investment bank sectors, and is able to offer both buy-side and sell-side perspectives. Mr. Freedman is a member of the board of directors of the Wall Street Tax Association, as well as a past-president and past-chairman of its Federal Tax Committee. He is also a member of the Managed Funds Association Tax Committee and has participated in a number of industry group efforts through the Securities Industry and Financial Markets Association and the International Swaps and Derivatives Association. Mr. Freedman is a frequent speaker on topics that include alternative investments, financial products, and other tax issues related to the financial services industry and is a co-author of KPMG’s Derivatives Tax Handbook.

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Sam Riesenberg
Partner
Mayer Brown International, LLP

 Mr. Riesenberg has significant experience with private credit, private equity, M&A, fund formation, infrastructure funds, investment structuring and tax issues involving asset management and operational activities, with a client base comprising fund sponsors, sovereign wealth and pension funds, institutional investors, family offices and fund managers. Clients turn to Mr. Riesenberg for advice in the areas of asset management and fund matters across the US, Europe, and the Middle East. 

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Brett Fieldston
Principal
KPMG Law, LLP

 Mr. Fieldston is a Principal in KPMG’s International Tax group, specializing in asset management and investment funds. He advises U.S. and global asset managers on investment and investment fund structuring, as well as management companies, with respect to a wide-spectrum of cross-border and U.S. international taxation issues.

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Description

Foreign investors in U.S. real estate are subject to stiff taxes and reporting requirements. The Foreign Investment in Real Property Tax Act (FIRPTA) requires nonresident withholding of 15 percent on the sales price of U.S. property, rather than the net gain, and nonresidents must file U.S. returns to recoup the over-withheld taxes. Additionally, 30 percent withholding is required on rental income. Using a U.S.-based blocker corporation can help certain investors circumvent these harsh tax consequences.

Acquiring real estate investments through a U.S. corporation, a leveraged blocker, allows nonresidents to acquire real estate interest through a U.S. entity. These entities can ease the burden of higher tax rates and onerous filing obligations required of foreign investors. However, leverage blockers may not be the best choice for all scenarios and the relative transactions between the corporation and the investor must be arms-length. Applicable tax rates, including state and local taxes, should be be considered and calculated. Tax practitioners working with foreign investors must weigh the pros and cons based on each foreign investor's tax situation.

Listen as our panel of international tax management experts explains how nonresident investors in the U.S. can utilize leverage blockers to minimize U.S. filing and payment obligations.

Outline

  1. Leveraged blockers: introduction
  2. U.S. taxation of nonresident investors
  3. Benefits of leveraged blockers
  4. Structuring a leveraged blocker corporation
  5. Transfer pricing analysis
  6. Caveats and other considerations
  7. Alternative investment options

Benefits

The panel will review these and other critical issues:

  • U.S. taxation of nonresidents
  • Foreign investors and situations that are ideal candidates for leveraged blockers
  • Alternative investment options when a leveraged blocker corporation is not ideal
  • Weighing the benefits and caveats of a leveraged blocker structure for specific foreign investors

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify foreign investors who might benefit from a leveraged blocker corporation
  • Determine the tax consequences of using a leveraged blocker
  • Ascertain caveats to consider for certain foreign investors
  • Decide how to structure a leveraged blocker

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).