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Business Journals
03-07-2025
- Business
- Business Journals
Nonresident investment in U.S. real property: The importance of planning ahead
U.S. residential and commercial real estate has been a popular source of investment for foreign persons for decades and easily exceeds $100 billion dollars on an annual basis. Because of the unique way that the U.S. taxes nonresident individuals and entities on the sale of U.S. real estate, it is crucial to plan before acquiring or selling such investments. This article briefly discusses the U.S. tax rules related to nonresident investments in U.S. real estate assets. Foreign Investment in Real Property Tax Act Nonresident individuals and entities are generally exempt from U.S. tax on the sale of most types of U.S. capital assets, including investment securities. However, this tax exemption does not extend to nonresidents' sale of U.S. real property interests. Nonresidents' disposition of U.S. real property interests is governed by the U.S. tax regime known as the Foreign Investment in Real Property Tax Act ('FIRPTA'). FIRPTA provides a comprehensive set of rules for taxing both the sale of real property interests and the direct or indirect transfer of U.S. real property interests within a family or group of related entities. What is a U.S. real property interest? Under FIRPTA, a 'U.S. real property interest' includes direct ownership of U.S. real property by a nonresident individual or entity, other than as a creditor. Relevant U.S. real property interests include directly owned land, residential property, and commercial property. A U.S. real property interest also includes an interest (other than as a creditor), in a U.S. corporation whose U.S. real property interests equal or exceed 50 percent of the fair market value the company's assets. This type of corporate U.S. real property interest is referred to as a U.S. Real Property Holding Corporation ('USRPHC'). A nonresident's sale or transfer of either type of U.S. real property interests is subject to the U.S. FIRPTA rules. When does FIRPTA come into play? FIRPTA tax is triggered when a non-resident individual or a foreign entity sells or transfers their U.S. real property interest. Complex FIRPTA rules also apply to certain transfers of real property that are carried out via transactions that would otherwise qualify as tax-free reorganizations. How is a sale or transfer of U.S. real property taxed? When a nonresident sells or disposes off a U.S. real property interest that is subject to FIRPTA tax, the acquiror (individual or entity) is required to withhold 15% on the gross amount realized by the seller. The gross 'amount realized' includes the cash paid to the nonresident seller, the fair market value of any other property transferred, as well as any outstanding liabilities attached to the U.S. real property interests. Subject to fulfillment of certain conditions, the transferor may apply to the U.S. Internal Revenue Service for non-applicability or reduced rate of withholding tax. Processing times for these certificates can take several weeks, so this should be considered well in advance when undertaking any transactions. Nonresident seller or transferor generally required to file a U.S. income tax return? In addition to being subject to U.S. withholding tax, a seller must file a U.S. income tax return for the year of disposition to report the disposition. To the extent the withholding tax on the gross sales price exceeds the U.S. tax that would be applied on a net basis (i.e., after taking into account applicable deductions), the nonresident seller may request a refund of excess amounts withheld. For nonresident companies, the applicable tax rate that would apply on net proceeds of real property sales or dispositions is 21 percent, while the tax rate for individuals would be the applicable graduated tax rate (between 10 and 37 percent). Advanced planning is crucial prior to acquisition or sale of U.S. real estate To ensure that nonresidents' investments in U.S. real property is undertaken as tax efficiently as possible, it is important that careful consideration be given to the following items: Our international tax group has extensive experience is helping nonresidents with the acquisition and disposition of U.S. real property and our dedicated team of specialists would be happy to assist you to ensure that your investment is carried out as efficiently as possible. . At Mowery & Schoenfeld, we support companies and individuals engaged in cross-border investments and business. Whether you're considering market entry into the U.S. from abroad, expanding from the U.S. to global markets, an international transaction, or optimizing your existing multinational operations, we will help develop and implement the right strategies. For more information, visit our website or contact us at international@
Global News
28-05-2025
- Politics
- Global News
Trump plans to pardon Todd and Julie Chrisley, convicted of fraud, tax evasion
U.S. President Donald Trump announced that he's planning to pardon Todd and Julie Chrisley, best known for their reality show Chrisley Knows Best, which followed their tight-knit family and extravagant lifestyle that prosecutors said was boosted by bank fraud and hiding earnings from tax authorities. In 2022, Todd was sentenced to 12 years in prison and his wife Julie was set to serve seven years behind bars after both were found guilty on charges of bank fraud, tax evasion and conspiring to defraud the U.S. Internal Revenue Service (IRS). Julie was additionally convicted of wire fraud and obstruction of justice. The Chrisleys were each ordered to serve three years of supervised release after their prison sentences and were to pay US$17.8 million in restitution. The couple conspired to defraud banks in the Atlanta area out of more than $30 million in loans by submitting false documents. They were also found guilty of tax evasion after obscuring their earnings while showcasing a luxurious way of living that authorities said included high-priced cars, designer clothes, real estate and travel. Story continues below advertisement Prosecutors said the Chrisleys walked away from their responsibility for repayment when Todd declared bankruptcy and left $20-plus million in unpaid loans. 'It's a great thing because your parents are going to be free and clean and I hope that we can do it by tomorrow. Is that OK? We'll try getting it done tomorrow,' Trump said in a call with their daughter, Savannah Chrisley, according to a video posted online by White House aide Margo Martin. 'I don't know them but give them my regards and wish them a good life,' Trump said to Savannah on Tuesday. 'Thank you so much, Mr. President,' Savannah replied. 'They've been given a pretty harsh treatment based on what I'm hearing,' Trump said of the Chrisleys a few moments later. BREAKING! President Trump calls @_ItsSavannah_ to inform her that he will be granting full pardons to her parents, Todd and Julie Chrisley! Trump Knows Best! — Margo Martin (@MargoMartin47) May 27, 2025 Story continues below advertisement In a social media post, the aide declared, 'Trump Knows Best!' Savannah took to X to celebrate the news, writing, 'This moment is bigger than just my family…it's about an administration that believes in second chances, that restores families, and that brings hope back to the American people.' 'To President Trump @realDonaldTrump and his team—thank you for believing in justice over vengeance. My fight was born out of love, but it was sustained by faith, truth, and the unshakable belief that our system should right its wrongs,' she added. 'To every child, spouse, and parent still fighting for their loved one—don't stop. Your voice matters. Your story matters. And I'll keep fighting for you, too.' Thank you, @KariLake. I am deeply humbled by your words. This moment is bigger than just my family…it's about an administration that believes in second chances, that restores families, and that brings hope back to the American people. To President Trump @realDonaldTrump and his… — Savannah Chrisley (@_ItsSavannah_) May 28, 2025 Story continues below advertisement Savannah also took to Instagram after she received the phone call from Trump and shared details of the conversation in a video posted to her nearly three million followers. Get daily National news Get the day's top news, political, economic, and current affairs headlines, delivered to your inbox once a day. Sign up for daily National newsletter Sign Up By providing your email address, you have read and agree to Global News' Terms and Conditions and Privacy Policy 'The president called me personally as I was walking into Sam's Club and notified me that he was signing pardon paperwork for both of my parents,' she said in the video, while wearing a gold Make America Great Again hat. 'So, both my parents are coming home tonight or tomorrow and I still don't believe it's real. I'm freaking out. The fact that the president called me, I will forever be grateful for President Trump, his administration and everyone along the way,' she said. She added that she was preparing to pick up her parents and getting the house ready for their return. 'We're getting some clothes together for mom and dad, getting their room put together upstairs, and I'm just speechless. I can't thank you guys enough for sticking with my family along the way and for loving us and supporting us,' she added. 'My parents get to start their lives over,' Savannah continued. 'President Trump didn't just commute their sentences. He gave them a full, unconditional pardon. So for that I am forever grateful. 'Thank you, President Trump. I vow to stand next to you and your administration and exposing the corruption and continue fighting for the men and women that are in prison. I will repay your kindness to every person I meet. Thank God for a president like Donald J. Trump.' Story continues below advertisement Harrison Fields, the principal deputy press secretary and special assistant to Trump, confirmed the president's plan to pardon the Chrisleys in a statement to The Hollywood Reporter. 'The President is always pleased to give well-deserving Americans a second chance, especially those who have been unfairly targeted and overly prosecuted by an unjust justice system,' Fields said. 'President Trump called Savannah and her brother from the Oval Office to personally inform them that he would be pardoning their parents, Todd and Julie Chrisley, whose sentences were far too harsh.' Story continues below advertisement On Monday, Trump also pardoned Scott Jenkins, a former Virginia sheriff who was sentenced to 10 years in prison after being convicted on fraud and bribery charges. The president posted online that Jenkins and his family 'have been dragged through HELL by a Corrupt and Weaponized Biden DOJ.' Trump has also moved to pardon Paul Walczak, a Florida health-care executive imprisoned on tax charges, whose mother helped expose the contents of a diary kept by Ashley Biden, daughter of former president Joe Biden. And, in April, he pardoned Nevada Republican Michele Fiore, who was awaiting sentencing on federal charges that she used money meant for a statue honouring a slain police officer for personal costs, including plastic surgery. The Chrisleys' lawyer, Alex Little, said the pardon 'corrects a deep injustice and restores two devoted parents to their family and community.' 'President Trump recognized what we've argued from the beginning: Todd and Julie were targeted because of their conservative values and high profile. Their prosecution was tainted by multiple constitutional violations and political bias,' Little said in a statement. 'Todd and Julie's case is exactly why the pardon power exists. Thanks to President Trump, the Chrisley family can now begin healing and rebuilding their lives.' Before the Chrisleys became reality television stars, they, and a former business partner, submitted false documents to banks in the Atlanta area to obtain fraudulent loans, prosecutors said during their trial. They accused the couple of spending lavishly, then using new fraudulent loans to pay off old ones. Story continues below advertisement A three-judge panel of the 11th U.S. Circuit Court of Appeals last summer upheld the Chrisleys' convictions but found a legal error in how the trial judge had calculated Julie Chrisley's sentence by holding her accountable for the entire bank fraud scheme. The appellate panel sent her case back to the lower court for resentencing. Savannah spoke at the 2024 Republican National Convention, where she talked about her parents' imprisonment. She said then that they were 'persecuted by rogue prosecutors' — echoing Trump's rhetoric about the criminal justice system as he faced investigations and criminal cases of his own. She said Trump had been targeted for his politics, and said her parents likewise were targeted because of their conservative beliefs and high profile. 'I'll never forget what the prosecutors said in the most heavily Democratic county in the state, before an Obama-appointed judge. He called us the 'Trumps of the South,'' Savannah said in her remarks at the convention. 'He meant it as an insult but, let me tell you, boy, do I wear it as a badge of honour.' Story continues below advertisement The news of the Chrisleys' pardon comes one week after Lifetime announced the family's return to reality TV with a new docuseries, titled The Untitled Chrisleys Project. The new docuseries will be 'pulling back the curtain' on the Chrisleys, with 'unprecedented access to their lives in a deeply personal and dramatic new series.' The family's first show, titled Chrisley Knows Best, aired for 10 seasons from 2014 through 2023 and followed the tight-knit, boisterous family living in the Nashville area. Much of the series emphasized Todd's obsessive yet comedic efforts to keep tabs on three of his kids, two of whom were in their 20s, and his mother. The series had a spinoff called Growing Up Chrisley, featuring his kids Chase and Savannah, who moved to Los Angeles. It aired for four seasons after premiering in 2019. Todd also briefly hosted a talk show, According to Chrisley, for the network. Todd and Julie also had a podcast called Chrisley Confessions. — With files from The Associated Press
Forbes
14-04-2025
- Business
- Forbes
Five Requirements For Filing Taxes For Free Using IRS Direct File
WASHINGTON, DC - SEPTEMBER 15: A sign marks the entrance to the U.S. Internal Revenue Service (IRS) ... More headquarters building on September 15, 2024, in Washington, DC. (Photo by J.) With taxpayers paying hundreds of dollars to complete and file their income tax returns each year, the IRS has rolled out a free program called IRS Direct File to taxpayers in 25 states. While this program could save taxpayers a lot of money, some taxpayers will not qualify. This article discusses the qualifications to help taxpayers determine if the IRS Direct File program can be used for the upcoming tax filing deadline. April 15th marks the deadline for individuals to submit their 2024 income tax returns and pay their tax bills. Unlike the majority of taxpayers filing 2023 income tax returns, taxpayers in 25 states can file this year's tax returns for free directly with the IRS. The new program called IRS Direct File has been piloted across a smaller sample of states in recent years before offering it out to a much larger swath of the population for this year's filing season. Despite the inherent financial benefit of now being able to file taxes without using tax prep software or a CPA firm, many taxpayers still do not know much about this new program. IRS Direct File is a historic and novel program designed to allow taxpayers to complete and file their taxes for free directly with the IRS. A key catch to this program is that it is not available to everybody. In particular, participation in this program follows five key criteria: Assuming all five requirements are met, the IRS Direct File provides substantial cost savings to taxpayers. For instance, it is estimated that the average cost to file a simple tax return using a CPA is $220. This amount is comparable to tax software providers like Turbo Tax, which advertises costs at over $100 to help taxpayers do their taxes themselves or over $200 for filing taxes with the assistance of an expert. Importantly, these cost savings are borne by those who benefit from it the most, as those with high wages are not eligible for this service. Lastly, the Direct File program limits the uncertainty of taxpayers filing their tax returns as these are remitted directly to the IRS. However, not all are on board with this service. The Department of Government Efficiency (DOGE) claims that this service is an illegal and blatant power grab due to the use and access of personal taxpayer information. In a Business Insider article, this agency also claims that these services belong to the private sector and that putting them under the federal government's purview is inefficient. Despite the concerns over the plausibility of the IRS Direct File program, it remains available for filing 2024 income tax returns and could be expanded to more states in future years. As taxpayers near the April 15th deadline, they should be aware that this program is an option available to them for filing their 2024 income tax returns.
Yahoo
10-04-2025
- Business
- Yahoo
TRUE or FALSE: Does Georgia have a tax deadline extension for 2025?
It's April 2025. For most Americans, that means it's tax season and bills are about to come due. The national tax filing deadline is April 15, but in some states, there's been an extension due to damages from severe storms in 2024. So, is Georgia among the places with a tax deadline extension? True/False: True, Georgia is one of seven states to receive a tax deadline postponement from the U.S. Internal Revenue Service. The deadline extension was announced in October 2024, giving those in the qualifying areas until May 1 to file their taxes. [DOWNLOAD: Free WSB-TV News app for alerts as news breaks] TRENDING STORIES: GA 911 caller hears dispatcher ordering McGriddle during emergency call 6 charged after shooting at Marietta apartment complex leads to chase, crash Be weather aware: Damaging winds, large hail possible with storm risk today While seven states did receive postponements, not all of the states have the extension statewide. Alabama, Georgia and the Carolinas are extended for the whole of those states, but only 41 Florida counties, eight Tennessee counties and six counties and a single city in Virginia have extensions to May 1. For those who are getting the deadline extension, the IRS said the following people or entities qualify: Any individual or business that has a 2024 return normally due during March or April 2025. Any individual, business or tax-exempt organization that has a valid extension to file their 2023 federal return. The IRS noted, however, that payments on these returns are not eligible for the extra time because they were due last spring before the hurricane occurred. 2024 quarterly estimated income tax payments normally due on Jan. 15, 2025, and 2025 estimated tax payments normally due on April 15, 2025. Quarterly payroll and excise tax returns normally due on Oct. 31, 2024, and Jan. 31 and April 30, 2025. For businesses that make payroll and excise tax deposits, the IRS is also making penalty relief available. More information is available online here. [SIGN UP: WSB-TV Daily Headlines Newsletter]
Yahoo
04-04-2025
- Business
- Yahoo
Fact Check: Yes, the IRS allows tax deductions on some pet expenses, like service animals
Claim: For tax filing year 2024, the U.S. Internal Revenue Service was allowing deductions on pet expenses. Rating: What's True: It was indeed possible to claim tax deductions in certain scenarios, such as medical costs for licensed service animals, performance animals, donations to qualifying nonprofits that support animal welfare, or pet-related moving costs for active-duty service members forced to relocate due to orders. What's False: However, pets couldn't be claimed as dependents in the same way as qualifying children or relatives. Further, tax deductions for service animals existed before the 2024 filing year. As the deadline for U.S. citizens to file their 2024 tax returns loomed in late March 2025, claims pertaining to purported tax deductions for pet owners circulated on social media. Multiple users on Instagram (archived, archived), TikTok (archived) and Threads (archived) posted about this alleged "exciting news for pet owners," though most posts buried crucial context, if it was present at all. Nearly all instances claimed these pet-related deductions began in the tax-preparation year of 2025 (for 2024 filings). @mikeagrusslaw Take advantage of this for your pets! 🙌 #taxdeduction #taxseason #taxbenefits #taxes2025 #pets #lawyer ♬ original sound - MikeAgrussLaw Some truth exists to the claim that the IRS allows certain tax deductions on pet expenses, but critical requirements must be met. According to the Internal Revenue Service (IRS) and tax preparation services, these deductions are not simply for standard pet owners, nor can pets be claimed as a dependent in the same way as qualifying children or relatives. Rather, most pet-related deductions pertain to care for a licensed service animal, according to the IRS' Publication 502, which also "explains the itemized deduction for medical and dental expenses that you claim on Schedule A (Form 1040)." Further, these service-animal deductions have been possible before 2024. For example, Publication 502 for the filing year 2008 also cites possible deductions for service animals. For all of these reasons, we've rated this claim as a mixture of truth and falsehood. The "Guide Dog or Other Service Animal" section of Publication 502 for the filing year 2024 reads: You can include in medical expenses the costs of buying, training, and maintaining a guide dog or other service animal to assist a visually impaired or hearing disabled person, or a person with other physical disabilities. In general, this includes any costs, such as food, grooming, and veterinary care, incurred in maintaining the health and vitality of the service animal so that it may perform its duties. Important to note is the language above specifies "physical disabilities." On a page dedicated to tax deductions on the National Service Animal Registry website, the organization adds that "you are only eligible if your medical expense exceeds 10% of your Adjusted Gross Income (AGI)," which would include "wages, business income, dividends, and other income." The blog for Intuit TurboTax, a tax preparation service, cites additional instances that may allow for pet-related tax deductions, such as owning a business that requires the use of animals. This could include performance animals (such as those used on a movie set) or even those that work as a social media influencer. TurboTax says: If your pet is making money as an influencer, it could be viewed by the IRS as your own self-employed business if your pet is generating income for you in the dog modeling/acting category on a regular basis. In some cases, pet-related expenses could be considered business expenses and offset against your pet's earnings. TurboTax also cites expenses related to fostering animals from a qualified 501(c)(3) organization as a potential write-off, including pet food, veterinary bills and supplies. IRS Publication 526 additionally cites donations related to qualified nonprofit organizations that "are religious, charitable, educational, scientific, or literary in purpose, or that work to prevent cruelty to children or animals" are also eligible for deduction. Newsweek points out other scenarios where pet expense tax deductions may be possible: For "active-duty military member[s] moving due to orders, pet relocation costs can still be claimed as part of moving expenses." The Newsweek article also states, "For those setting up a pet trust, legal fees associated with establishing the trust may be deductible in some cases. However, routine pet expenses such as food and toys are still not deductible under personal tax returns." However, tax deductions can be complex, nuanced and particular to an individual's financial holdings and employment status. This article should not be considered financial advice. Please visit a qualified financial adviser if you have questions about items that may be eligible for tax deductions. About Publication 502, Medical and Dental Expenses | Internal Revenue Service. Accessed 1 Apr. 2025. "Can You Claim Pets on Tax Returns? What to Know." Newsweek, 1 Feb. 2025, Codys. "Service Animal Tax Deductions: Maximizing Tax Benefits." NSARCO, 27 Apr. 2022, Dependents | Internal Revenue Service. Accessed 1 Apr. 2025. Publication 526 (2024), Charitable Contributions | Internal Revenue Service. Accessed 1 Apr. 2025. TurboTaxBlogTeam. "Is There a Pet Tax Credit? Are Pet Expenses Deductible?" Blog, 22 Jan. 2024,
