Foreign Tax Credits cannot be used to claim back personal income tax paid in the US against corporate income tax due in Canada, and the CRA is now saying they see that income as corporate income.   

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Neither had thought that there are some passive opportunities to put some of their funds into solid apartment syndication deals using the 1031 exchange.  

I have been exchanging emails with his assistant but since I am new I felt that I should check with you guys and vet this opportunity.

It was a case where she said he offered her more shares of his ******** company in exchange for sex.

The IRS determines real estate dealer status based on the "intent" of the taxpayer holding or buying the property.The characterization of gain or loss on the sale or exchange of real property turns on whether the property was held "primarily" for sale or investment.The Courts have come up with their top fifteen items that they look for in determining the status:1.

I work with a real estate marketing company and here is what they have suggested:- I'd recommend using a tangible item of value for your campaign (something given to the prospect in exchange for their contact information) -- in your case, my thought would be a free initial meeting or consultation.  

I work with an international attorney to structure partnerships with foreign investors.

A borrower gives a Mortgage (or similar instrument) and a Promissory Note to the Lender in exchange for the Lender to give the Borrower money.

Both the LLC's are owned by the primary residence owner.2) You pay the market rent for the primary residence to LLC and the depreciation of the primary residence as a rental property is large enough that covers the cost of running LLC and other costs and a bit more.3) You intend to live in your primary residence for 15+ years and at the end if you do decide to sell it, you would do a 1031 exchange rather than outright sell.Keeping the above in mind, what other downsides do you see for putting a primary residence in an LLC and renting to self?