Diosdi & Liu, LLP

04/16/2024

This article provides an overview of the U.S. federal tax rules governing U.S. beneficiaries of foreign trusts. The term “U.S. person means:

This article provides an overview of the U.S. federal tax rules governing U.S. beneficiaries of foreign trusts.

04/13/2024

If you’re seeking expert tax legal advice or representation in San Francisco, look no further than Diosdi & Liu, LLP.

If you're seeking expert tax legal advice or representation in San Francisco, look no further than Diosdi & Liu, LLP.

04/11/2024

The amount subject to withholding is the sum of cash paid, the market value of the property transferred, or the amount of liabilities to which the transferred property is subject.

FIRPTA is designed to ensure that a foreign investor is taxed on the disposition of a U.S. property interest.

04/09/2024

This article also provides a number of tax planning options that should be considered by foreign investors when acquiring U.S. real estate.

This article summarizes the U.S. tax consequences associated with a foreign investor’s acquisition of different U.S. property interests.

04/07/2024

This article discusses the IRS’s statutory ability to assess and collect Section 6039F Penalties associated with failing to timely disclose a foreign gift on a Form 3520.

04/05/2024

This article will discuss whether an entity has an obligation to file a Form 5472.

04/03/2024

The following types of foreign persons may be subject to U.S. withholding taxes:

With the expansion of cross-border transactions, more U.S. businesses will need to become familiar with U.S. tax, withholding, and compliance rules.

04/01/2024

A nonresident alien is an individual who is neither a citizen nor resident of the United States.

With the expansion of cross-border transactions, more U.S. businesses will need to become familiar with U.S. tax, withholding, and compliance rules.

03/30/2024

When it comes to tax matters in San Francisco, finding reliable legal counsel is paramount.

Contact us today to experience the difference for yourself and take the first step toward achieving your financial goals with confidence.

03/28/2024

This article analyzes the Dynamo Holdings case, which is a blueprint of how inbound restructuring should be carefully addressed and handled.

Beekman Vista sold multiple properties to Dynamo Holdings through a number of bargain sales transactions that exceeded $200 million.

03/26/2024

This article will discuss whether an entity has an obligation to file a Form 5472.

A platform contribution transaction payment is not the equivalent of a licensing fee. Treasury Regulation Section 1.482-7(c)(4) provides:

03/24/2024

Generally, withholding agents are required to withhold U.S. tax at the source on certain payments made to nonresident aliens and foreign corporations.

Withholding taxes is effected primarily through the imposition of an obligation on the person or entity making the payment to the foreign person to withhold the tax and pay it over to the Internal Revenue Service or (“IRS”)