Jeffrey L. Rubinger

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Tax Planning for U.S. Companies with Latin American Operations

Pass-through structures Many South Florida-based companies conduct business operations throughout Latin America. Typically, these operations are conducted though wholly-owned foreign subsidiaries. With the corporate tax rates in these jurisdictions approaching the highest U.S. federal income tax rates (for example, the corporate income tax rate is 35% in Argentina, 34% in Brazil, and 30% in Mexico), many … Continue Reading

Expatriation Lite: Leaving the U.S. Tax System While Retaining Your Citizenship

As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income.  Therefore, a U.S. taxpayer that earns only foreign source income will be subject to U.S. federal income tax on … Continue Reading

Some Dividends Received from Cypriot Corporations not Eligible for Qualified Dividend Rates

When Is a Statutory Benefit a ‘Treaty Benefit’? When the IRS Says So! Since Section 1(h)(11) was enacted as part of the Jobs and Growth Tax Relief Reconciliation Act of 2003, questions have been raised on exactly how to interpret the section’s legislative history. Under this provision, a dividend received by a U.S. individual taxpayer (directly … Continue Reading

Unique Provisions in New U.S.-Chile Income Tax Treaty Should Lead to Increased Inbound Investment Once in Effect

Income Tax Treaty Only Third Signed with Latin American Jurisdiction Since the U.S.-Chile Free Trade Agreement came into force in 2004, bilateral trade between these two countries has more than doubled. In fact, according to the Chilean Foreign Investment Committee, the United States is Chile’s second largest goods trading partner overall, and the largest foreign investor in … Continue Reading

Will The IRS Report Non-U.S. Taxpayers’ Bank Deposit Interest To Foreign Governments?

Banks’ Reporting Requirements Raise Privacy Concerns Effective January 1, 2013, U.S. financial institutions will be required to annually report bank deposit interest earned by non-U.S. residents to the IRS. Currently, U.S. financial institutions are only required to report bank deposit interest earned by residents of Canada to the IRS. (It should be noted that such … Continue Reading

Florida Residency Required for Homestead Protection

One of the top reasons for moving to Florida, aside from the year-round sunny weather and the multitude of exciting things to do, is the homestead protection afforded to Florida residents. Article X, §4(a) of the Florida Constitution protects Florida homestead property from levy and execution by an owner’s creditors during the owner’s lifetime. Under … Continue Reading

Tax Structuring of Foreign Investment in South Florida Real Estate

Foreign Investment In South Florida Real Estate Heats Up According to a recent report, international buyers are driving sales at several large real estate projects in South Florida. The 200-unit Trump Hollywood sold out less than two years after lenders foreclosed on the 41-story oceanfront tower. In Miami-Dade County, all 1,800 units at Icon Brickell … Continue Reading
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