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Society of Trust and Estate Practitioners ("STEP")

Silicon Valley Chapter

February 7th, 2013 Event:

EVENING PROGRAM

INBOUND US INVESTMENT AND PRE-IMMIGRATION TAX PLANNING FOR THE LATAM CLIENT

ROBERT F. HUDSON, JR.
Managing Partner and Senior Tax Partner of the Miami office of
Baker & McKenzie LLP

1.    Foreign investment in US real estate structuring. This topic will address the widely different US tax results that will apply depending upon the choice of entities and debt elements used by the non-US investor, ranging from the quite simple and direct options thru highly sophisticated (and more complex) structures that produce better than normal US tax consequences, even for foreign corporate investors and those seeking public confidentiality regarding their US real estate interests

.2.    Pre-immigration US tax Planning. This second topic addresses the traps for the unwary and tax planning opportunities that a non-US person can avail themselves in the calendar year before they may first become a US tax resident, including stepping up the basis of highly appreciated assets, ensuring that passive income generating assets will not be subject to CFC and PFIC regimes, that significant foreign tax credits will be usable once in the US, estate tax planning techniques are not overlooked and similar US income, gift and estate tax planning issues.

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Speaker:

Mr. Hudson is the managing partner and senior tax partner of the Miami office with 40 years of experience in international tax law. He has long been recognized as a leading tax authority and practitioner, with specialties in both tax planning and tax controversy work in the international and domestic arenas, with a subspecialty of addressing FIRPTA and treaty-related issues for foreign clients investing in the United States.  Bob has written extensively, publishing over 80 articles to date.  He also lectures regularly before a wide variety of professional organizations throughout the world.

Mr. Hudson is consistently top -ranked by Chambers Global, Chambers USA, Citywealth’s Leading Lawyers, Who’s Who in the world, Who’s who in America Law, and Euromoney’s guide to the World’s Leading Tax Advisers and Euromoney’s Guide to the World’s Leading Trusts and Estate Practitioners. He is one of the few lawyers in the US that have been listed in Best Lawyers in America for over 20 years.

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