Creating tax-efficient structures for foreign taxpayers investing in the United States has long formed a core part of Jon’s practice, including:
- Creating tax structures and guidelines for foreign entities and their owners to avoid conducting a trade or business in the United States and becoming subject to U.S. federal income tax.
- Forming “blocker” entities for foreign investors making U.S. investments who want to avoid any U.S. income tax return filing obligations.
- Forming “reverse hybrid” blocker entities to allow foreign investors to claim treaty benefits for reduced U.S. withholding tax on their U.S.-source investment income.
- Tax-efficient investment in, and exit from, U.S. real estate for both individuals and institutional investors.
- Advising investment fund managers and sponsors on structuring investments in U.S. loan portfolios so that the interest income is not subject to U.S. income tax as income from “loan origination.”
Jon has experience with investors and entities investing in the United States from the UK, Canada, Germany, Netherlands, France, Russia, India, Hong Kong, Ireland, Luxembourg, and Singapore.