Henry,
It was probably my comment you are referring to.
Here is a site with many if not all (at that date) of the US treaties
on the subject.
http://www.unclefed.com/ForTaxProfs/Treaties/index.html
The site does not include treaties for UAR and Kyrgyzstan.
As I understand it from my recollection of the treaty with Germany,
where I (US citizen) live, I believe income from sale of real estate
is only taxed in that country, and that there is no right of off-set
against tax in the other country, and, I believe, it does not matter
whether you are living abroad or in the USA.
Using a nominee could well complicate matters. I know, for example,
that income from sale of land held by a US "S corporation", although
that income is treated by the IRS as personal long term income, in
Germany, which does not recognize the US treatment of S Corporations,
the income is considered to be normal, fully taxable personal income
when distributed.
On the other hand, because the US does not have a tax on capital
assets - a wealth tax - the IRS doesn't know everything ...
You should also know that the IRS and some foreign countries do
exchange information about income of their citizens living in the
other country - just to keep us honest (but the system is not
perfect).
As you can read in the disclaimer below, this is not legal or
professional advice. And as you can see above, I am only sure about
the information on Germany's treatment of S corporations and that in
the previous paragraph.
Nonetheless, if you have further question, I will try to help.
Regards, Myoarin |