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New Bloomberg BNA Webinar Examines Tax Structuring Considerations for Foreign …

ARLINGTON, Va., March 27, 2012 /PRNewswire via COMTEX/ —
The depressed state of the U.S. real estate market continues to attract foreign investors who see long-term opportunities in both commercial and residential property despite the Foreign Investment in Real Property Tax Act’s withholding tax imposed on the transfer of U.S. real estate by a non-resident alien.

“In determining the appropriate ownership vehicle for U.S. property, whether U.S. LLC; foreign corporation, U.S. corporation or individual ownership, counsel for foreign investors must balance a variety of tax consequences, U.S. income, capital gains and estate taxes,” says Allen Appel, Esq., Of Counsel in the New York office of Bryan Cave LLP and copresenter with Jack Mandel (also Of Counsel to Bryan Cave) of a new Bloomberg BNA webinar, Tax Structuring Considerations for Foreign Investors in U.S. Real Estate.

This webinar will review tax strategies for foreign investors in U.S. real estate to structure the purchasing entity as well as tax planning opportunities for structuring the deal. In 60-90 minutes, the presenters will cover:

I. Investment structure alternatives

Individual ownership

Ownership via U.S. LLC

Ownership via foreign corporation

Ownership via U.S. corporation

Other entity structures

II. Tax consequences for investment structures

U.S. income tax

U.S. capital gains rate

U.S. estate tax


III. Tax strategies for structuring the deal

Tiered entities

Other strategies

About the Speakers

Alan Appel, Counsel, Bryan Cave LLPAlan Appel focuses his practice in international and domestic tax planning involving taxation of mergers and acquisitions, partnerships, joint ventures, limited liability companies and tax controversy matters. Mr. Appel began his career as a trial attorney in the Office of Chief Counsel, Internal Revenue Service in Washington, D.C., and New York City. On behalf of the American Bar Association Tax Section, Mr. Appel had primary responsibility for drafting and submitting comments to the U.S. Treasury Department and IRS concerning the scope of the guidance provided by the proposed regulations under Section 1446 of the Internal Revenue Code and also was asked by the Office of the Chief Counsel to train its attorneys on this issue. Mr. Appel recently published two articles on the Section 1446 regulations in The Journal of International Taxation, a third article in the Tax Management Memorandum and a fourth article in the Tax Management International Journal.

Mr. Appel is on the Board of Advisors for the Journal of International Taxation and the Journal of Taxation and Regulation of Financial Institutions. He has published articles in The Journal of Taxation, Tax Management Memorandum, Tax Management International Journal, The Journal of International Taxation, the New York Law Journal and the Westchester Bar Journal. Mr. Appel has appeared on both radio and television discussing various income tax issues. Mr. Appel is a member of the adjunct tax faculty of the New York Law School.

Jack Mandel, Of Counsel, Bryan Cave LLPDuring his more than 30 years of practice, Jack Mandel has been actively involved in the tax structuring of joint ventures and real estate related transactions. He has designed tax efficient structures in transactions involving real estate funds, REITs and hedge funds. He has significant experience in the unique income tax concerns of tax exempt investors, including unrelated business taxable income. He has counseled real estate families on tax efficient succession strategies and the division of real estate assets. He has represented foreign clients investing in the U.S. He has been heavily involved in the income tax aspects of debt restructurings and workouts. He has worked closely with clients on Section 1031 like kind exchanges and other disposition strategies. He regularly counsels clients on tax issues related to limited liability companies, partnerships and S corporations. He also has extensive experience with the New York State and City transfer taxes, mortgage recording tax and other state and local taxes. Mr. Mandel has served on various ad hoc bar association and real estate industry committees. In addition, he has lectured and written about real estate-related tax matters.

Tax Structuring Considerations for Foreign Investors in U.S. Real Estate takes place March 28, 2012 from 11:30 p.m. – 1:00 p.m., (ET). To register for this webinar and obtain further information about CLE and CPE credits, go to or (in the U.S.) call 800.372.1033, menu Option 6, then Option 1. The per site fee is just $249.

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About Bloomberg BNA Webinars Bloomberg BNA is the foremost source of tax and accounting research, news, practice tools, and guidance for tax attorneys, CPAs, corporate tax managers, estate planners, and financial accountants. Designed for today’s busy practitioners, our webinars offer the same expertise and relevance that are the hallmark of all Bloomberg BNA resources. In just 60-90 minutes, practitioners gain in-depth knowledge on a current tax or accounting topic from experts in that area — and benefit from practical applications that can be put to work immediately. Conference attendees have the opportunity to ask the speakers questions, and may be eligible to earn CLE or CPE credits — all from the convenience of their own office or conference room.

About Bloomberg BNA Bloomberg BNA, a wholly-owned subsidiary of Bloomberg, is a leading source of legal, regulatory, and business information for professionals. Its network of more than 2,500 reporters, correspondents, and leading practitioners delivers expert analysis, news, practice tools, and guidance – the information that matters most to professionals. Bloomberg BNA’s authoritative coverage spans the full range of legal practice areas, including tax accounting, labor employment, intellectual property, banking securities, employee benefits, health care, privacy data security, human resources, and environment, health safety.

SOURCE Bloomberg BNA

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