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Structuring Investments by Foreign Persons in U.S. Real Estate  


Author:  Alan I.  Appel .


Source: Volume 25, Number 05, May/June 2012 , pp.55-59(5)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

This article describes the basic principles of U.S. federal income tax liability under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) and the withholding mechanism that ensures collection of the tax. In addition, it sets forth some structuring alternatives to limit a foreign investor’s tax exposure with respect to the ownership and subsequent disposition of U.S. real estate.

Keywords: Foreign Investment in Real Property Tax Act; tax withholding; investment structuring; double taxation; estate taxation; tax reporting

Affiliations:  1: Bryan Cave LLP.

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