LLC, Utilization of Depreciation and Losses.
The Smith family are an Australian based family office. They are currently looking to invest in the U.S. real estate hedge fund based in Atlanta which requires a 5 year commitment. The hedge fund is...Read more
How do Family Offices determine whether to invest by way of debt or equity?
The Patel family are a Mumbai based family office. They are regularly given the opportunity to co-invest alongside U.S. based hedge funds in various private equity deals. The family’s holdings are structured out of India,...Read more
How do family offices optimize foreign tax credits in the U.S.?
The Clark Family are a U.K. based family office. They have an established manufacturing business in the U.K. and Asia that has allowed them to accrue substantial amount of capital outside of the family business. ...Read more
When no income tax treaty exists, when will the Closer Connection Test override the Substantial Presence Test?
Consider the same fact pattern but rather than John residing in the U.S. on an E2 Visa he is residing in the U.S. on a H1B Visa and rather than being from Australia he is...Read more
How do you apply the Substantial Presence Test?
John is single and he is currently exploring the possible expansion of his business from Australia into the U.S. He has a leased a home in West Hollywood and sold he home in Australia and...Read more