CASE STUDY 3:
Francois is an EU citizen residing in an EU country and is looking for a $3mm investment property to rent out in new york city for himself and his family. He has health issues and is of relatively advanced age. While considering a “foreign blocker” entity, most popular jurisdictions located in “fiscal paradises” were not acceptable due to his home country’s fiscal “black listing” of such jurisdictions. Instead, we formed a limited partnership in a non-fiscal paradise and filed for an election that treated such a limited partnership as its own separate entity for our tax purposes, while remaining transparent in the home jurisdiction. This protected against US estate tax while allowing optimal tax treatment in the client’s home country.
Click here to read the 1st Case Study: Case Studies for Trusts and Estates International Clients: Success Story 1 – Chaves Perlowitz Luftig LLP (cpllawfirm.com)
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