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How Will Irs Tax A Delaware Series Llc Owned Buy An Australian Self Managed Superannuaton Fund?

Discuss anything to do with property law - buying, selling property

How Will Irs Tax A Delaware Series Llc Owned Buy An Australian Self Managed Superannuaton Fund?

Postby Refr » Tue Dec 06, 2016 11:03 am

s About Taxes)/How will IRS tax a Delaware Series LLC owned buy an Australian Self Managed Superannuaton Fund? Advertisement Expert: MEdusa - 2/8/2011 A Self Managed Superannuation Fund in Australia will become the owner of a Delaware LLC.  The purpose of the LLC will be to purchase, own and collect rental income from properties around the US.  To be more specific the LLC will be a Series LLC.  My knowledge is that taxes will be passed through to the Aussie owner at their tax rate where the US will take their marginal tax rate based on total income earned by the individual and then get a credit which will go against having to pay double tax in Australia as they will have to pay the difference to Australia since Australia has a higher marginal tax rate.  The issue here is that the Self Managed Super Fund(SMSF) will be in pension phase and thus not incur any tax in Australia.  SMSF get taxed at 15% on the way in but no tax if in pension phase.  How will the US treat the rental income generated by the Series LLC?  The same question would be for capital gains as well.

ANSWER: way beyond cheap-oh free online tax chat.  how about hiring compentent tax advice?

---------- FOLLOW-UP ----------

The answer shouldn't be too difficult for an "expert".  The only way I can determine whether I'm dealing with an expert is to ask a question that not every joe shmo will know, thus finding the true expert.

ANSWER: And he is a smart a$$ too

IRS will tax the us sourced income regardless of the owner But if you think yours smells like strawberry shortcake. It is all yours and I won't even begin to help your righteous a$$!

---------- FOLLOW-UP ----------

So you have proven your lack of knowledge since every 6 year old knows that the US will tax regardless of the owner.  The answer is in the detail which you obviously are too ignorant to figure out.

You have some issues if you are trying list yourself as an expert on this site and all you can do is criticize others when they are searching for valid answers to valid questions.  I seriously hope you pull your head out one of these days so you can smell the roses and realize how true accounting professionals work, communicate and live life.

PS: wouldn't take your answers as valid anyway since you obviously don't know what you are talking about.  You're just a waste of time.  Good thing I have plenty of it.
Refr
 
Posts: 51
Joined: Mon Jan 13, 2014 9:31 pm

How Will Irs Tax A Delaware Series Llc Owned Buy An Australian Self Managed Superannuaton Fund?

Postby jarl » Thu Dec 08, 2016 8:05 pm

Here is the principal point you missed in my first reply

"way beyond cheap-oh free online tax chat.  how about hiring competent tax advice?"

The whole point of this forum is to answer questions for people who have quick and simple mis-understandings or need a nudge in the right direction.  It is not intended to be a full blown research and reference point for people trying to do tax and legal strategies.  what did you want, a "will" opinion???  duh.  I only give that for a fee(as does every other lawyer/CPA worth even a modicum of their salt).  

ALL I said in my first post, was that you needed to hire competent tax advice.. and I thought your question was beyond the scope of a free service.  Feel free to ask any of the other posters here and see if they take you down the yellow brick road to oz for free.   

There was no need to question my level of authority or knowledge or skills based upon my reply.  I also have the ability to reject questions as homework or other reasons too.  I almost clicked that button thinking you were a graduate student trying to gain an angle on your homework.  

Let me repeat myself.  There was no reason to question my level of knowledge or expertness based upon my rebuke suggesting you actually pay for advice of the level you were seeking.  

Next, I really don't need your validation to feel whole or to prove I am an expert in my field.  I post here as a pro bono community service to people who can't figure out how to take their divorced child as a dependent and to get EITC for a grandchild for whom they care for or to help with stuff like figuring out what an accountable plan is and how to get the best result from their 1099-A foreclosed home -- Not for fully funded global clients looking to take a cheap way around valid and thorough tax advice.  

Your question could be answered(and the deal structured) in any of a number of various ways - each with their own set of good and bad outcomes and commensurate risks.  Simple discussion here was not the point.  Your situation deserves more and you should be willing to pay for that level of knowledge and authority.  

I have 8 years advancing up to the level of Sr. Manager in National Tax firms and am now a managing director of a global consulting firm and at another private equity investment firm; I have two advanced degrees in tax and public finance, over 10 years teaching tax and finance for AACSB universities, clients from the UK, Sweden, Canada, Japan, Australia(one of my partners has a little flat around the corner from Bondi Beach in Sydney and he has consulted widely in Oz!) and two publicly traded SEC clients - one of which I was the CFO before taking an equity position. Just this week alone, I have met clients on restructuring global IP to avoid US tax(for the record - Singapore tax rates are under 20% and even with 482, we'll save that client in the hundreds of thousands of dollars... annually!) Trust me, my billing rate validates my status as an expert.   Not your drivel about me being a six year old. The way you 'find an expert' is not to ask questions about joe schmo, but to seek references, client correspondence, have a phone or person to person meeting, seek comment and advice.  I have made many presentations and proposals that were not won - but they were all based upon something more then a silly inquiry on a free chat board.   

And for the record, I am positive I could have saved you US cash as well as ensuring you meet the US/Oz tax treaties.  

grow up and go away!
jarl
 
Posts: 47
Joined: Fri Apr 01, 2011 5:35 am

How Will Irs Tax A Delaware Series Llc Owned Buy An Australian Self Managed Superannuaton Fund?

Postby Drayce » Sun Dec 11, 2016 7:02 am

s About Taxes)/How will IRS tax a Delaware Series LLC owned buy an Australian Self Managed Superannuaton Fund? Advertisement Expert: MEdusa - 2/8/2011 A Self Managed Superannuation Fund in Australia will become the owner of a Delaware LLC.  The purpose of the LLC will be to purchase, own and collect rental income from properties around the US.  To be more specific the LLC will be a Series LLC.  My knowledge is that taxes will be passed through to the Aussie owner at their tax rate where the US will take their marginal tax rate based on total income earned by the individual and then get a credit which will go against having to pay double tax in Australia as they will have to pay the difference to Australia since Australia has a higher marginal tax rate.  The issue here is that the Self Managed Super Fund(SMSF) will be in pension phase and thus not incur any tax in Australia.  SMSF get taxed at 15% on the way in but no tax if in pension phase.  How will the US treat the rental income generated by the Series LLC?  The same question would be for capital gains as well.

ANSWER: way beyond cheap-oh free online tax chat.  how about hiring compentent tax advice?

---------- FOLLOW-UP ----------

The answer shouldn't be too difficult for an "expert".  The only way I can determine whether I'm dealing with an expert is to ask a question that not every joe shmo will know, thus finding the true expert.

ANSWER: And he is a smart a$$ too

IRS will tax the us sourced income regardless of the owner But if you think yours smells like strawberry shortcake. It is all yours and I won't even begin to help your righteous a$$!

---------- FOLLOW-UP ----------

So you have proven your lack of knowledge since every 6 year old knows that the US will tax regardless of the owner.  The answer is in the detail which you obviously are too ignorant to figure out.

You have some issues if you are trying list yourself as an expert on this site and all you can do is criticize others when they are searching for valid answers to valid questions.  I seriously hope you pull your head out one of these days so you can smell the roses and realize how true accounting professionals work, communicate and live life.

PS: wouldn't take your answers as valid anyway since you obviously don't know what you are talking about.  You're just a waste of time.  Good thing I have plenty of it.
Drayce
 
Posts: 43
Joined: Tue Jan 21, 2014 2:14 am


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