Seth J. Entin, of Holland & Knight, has published an article, Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses Holland & Knight Alert (Feb. 20, 2020). The abstract is as follows:
- The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime, including many reforms that focus on multinational corporations. However, some lesser known TCJA provisions apply to foreign individuals.
- This Holland & Knight alert addresses a change to the U.S. “S” corporation rules that presents interesting opportunities for foreign individuals who wish to restructure their investments in U.S. real estate or operating businesses.
- This alert also includes a case study that demonstrates, in general terms, key U.S. income tax savings that can be obtained by converting from a “C” corporation structure to an “electing small business trust” (ESBT)/S corporation structure.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.