We advise off-shore clients regarding the sales and transfers of real estate in the United States (including the sales and transfers of entities owning real estate in the United States) and assist with all relevant filings required by the United States Internal Revenue Service. To the greatest extent possible in our tax planning, we make use of the “portfolio debt” rules which allow for the tax-free payment of interest on loans from off-shore persons and entities to entities in the United States. In addition, we advise clients with respect to the ownership of equity interests in entities located outside of the United States as well as all relevant reporting requirements.