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Treasury Proposes New Regulations on Disregarded Entities Owned by Nonresident Aliens

By Kenneth Zuckerbrot & Mary F. Voce on May 16, 2016
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If you ask the typical American tax administrator to name a notorious tax haven they would probably name the Cayman Islands or the British Virgin Islands or some other small nation that makes a disproportionate amount of its budget by accommodating international tax structures. Ask the same question of a European tax administrator and the answer will likely be Delaware or Nevada.

The ease and rapidity with which a U.S. Limited Liability Company (LLC) can be formed in these jurisdictions is a matter of wonder to many Europeans. More ominous, in their eyes, is the fact that the ownership of U.S. LLCS is not a matter of public record. Indeed, even the states in which the entities are formed generally do not have that information. An LLC can be established by an “incorporator,” who can be a lawyer, accountant, paralegal, or other person who has no interest in the company and no obligation to disclose the owners.

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Photo of Kenneth Zuckerbrot Kenneth Zuckerbrot

Kenneth Zuckerbrot Chairs the Bankruptcy Tax Group and represents public and private corporations and inbound and outbound investment companies in tax and real estate matters and has wide-ranging experience in debt restructurings. Ken’s experience in both International taxation and REIT work is combined…

Kenneth Zuckerbrot Chairs the Bankruptcy Tax Group and represents public and private corporations and inbound and outbound investment companies in tax and real estate matters and has wide-ranging experience in debt restructurings. Ken’s experience in both International taxation and REIT work is combined in the tax efficient acquisition structures of foreign real estate by U.S. REITs.

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Photo of Mary F. Voce Mary F. Voce

Mary F. Voce concentrates her practice on corporate and international tax. She handles both in-bound and out-bound corporate and international tax planning for U.S. and foreign corporations, U.S. federal taxation of partnerships, limited liability companies, funds and joint ventures. She also handles U.S.

…

Mary F. Voce concentrates her practice on corporate and international tax. She handles both in-bound and out-bound corporate and international tax planning for U.S. and foreign corporations, U.S. federal taxation of partnerships, limited liability companies, funds and joint ventures. She also handles U.S. federal tax aspects of cross-border corporate mergers, acquisitions and reorganizations, taxation of real estate investments, securities offerings by U.S. and foreign corporations, international projects, equipment leasing and financing.

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  • Posted in:
    Tax
  • Blog:
    GT Israel Law Blog
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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