The International Taxation department of Kerkering, Barberio & Co., P.A. is involved in all aspects of international taxation, including foreign companies and individuals who invest in United States real estate.

• Real property.
  
• Selection of business entities.
  
• Estate and gift.
  
• Change of residency.
  

Real Property
The rules surrounding the taxation of real property owned by foreign nationals can be quite complex. Our team of International Tax experts has specialized training and years of experience advising foreign companies and individuals who invest in U.S. real estate. In general, foreign ownership of U.S. real estate for personal usage does not result in any U.S. tax reporting until the property is sold or the owner of the property dies. The manner in which title to the real estate is held affects the U.S. taxation at death or sale. Consequently, we encourage non-resident aliens to seek our assistance prior to the purchase of U.S. real estate.

The rental of U.S. real estate by a non-resident alien is also subject to U.S. income tax, and there are rules relating to tax withholding for rental property owned by a foreign national. The foreign owner who rents property must obtain a U.S. taxpayer identification number. Again, the rules governing the rental of U.S. real property by a non-resident alien are complex and our years of experience in dealing with these laws can save clients significant time and expense.

Selection of Business Entities
Foreign individuals can operate businesses in the United States using a variety of structures. The choice of the appropriate structure for the type of business can be complex. The most commonly used structures are:

• U.S. corporation.
  
• Foreign corporation.
  
• Limited liability company.
  
• General partnership.
  
• Limited partnership.
  
• Sole proprietorship/individual ownership.
  

The choice of structure is equally important for U.S. companies and individuals operating overseas. These structures vary based on the country of operation and the type of business.

Estate and Gift
U. S. real property, investments in U.S. businesses and certain other property may be subject to U.S. estate taxation upon death of the owner or when the owner makes a gift of the property. Treaties with certain foreign countries and other tax planning techniques can reduce the amount of gift or estate tax due. We can explain these various techniques and coordinate with the non-resident alien's home country tax laws.

Change of Residency
It is imperative that a non-resident alien obtain advice with respect to pre-immigration tax planning before becoming a tax resident of the U.S. With proper planning, both income taxes and estate taxes may be reduced with respect to assets acquired before immigrating to the U.S.

Please contact Renea Glendinning, CPA* and her team to help you with International and other tax related matters.

* Licensed by the State of Florida.