Tag Archive: "FIRPTA"
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Foreign Considerations in Real Estate Dispositions
Foreign persons1 are generally not subject to Federal income tax on gains from the sale of a capital asset located in the United States, unless the capital gains are effectively connected with the conduct of a United States trade or business. Internal Revenue Code (IRC) Section 897, which came online with the passing of the […]
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Foreign Investment in U.S. Real Estate
Earlier this year, the IRS issued proposed regulations that could threaten how non-U.S. investors invest in real estate funds, private equity funds and other tax structures. The Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”) requires any gain realized by a non-U.S. investor from the sale or other disposition of a U.S. real […]