An overview of the FIRPTA provisions and recent regulatory developments
Article Abstract:
The 1980 Foreign Investment in Real Property Act (FIRPTA) added IRC s. 897, which governs the taxation of foreign investors in US real estate and the disposition of US real property interests, or USRPIs. Under 1996 regulations, the definition of a United States real property holding company has been amended. In addition, final withholding rate regulations governing IRC s. 1445 withholding were issued in Dec 1995. The IRS-Treasury 1996 Business Plan also details planned regulations further affecting USPRIs.
Publication Name: Journal of Real Estate Taxation
Subject: Real estate industry
ISSN: 0093-5107
Year: 1996
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Recent ruling highlights potential pitfall in corporate reorganization involving foreign investors of U.S. real estate
Article Abstract:
IRS Letter Ruling 9623028,indicates that foreign investors may be taxed under IRC Section 897(e) when they distribute US real property holding company stock in conjunction with corporate reorganizations. Investors may be able to comply with IRC Section 897(e) and utilize its nonrecognition exchange rules. The facts behind the letter ruling and its applicability to other foreign corporations are also discussed.
Publication Name: Journal of Real Estate Taxation
Subject: Real estate industry
ISSN: 0093-5107
Year: 1997
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Taxation of equity participation rights in U.S. real estate held by foreign investors
Article Abstract:
Foreign investors in US real estate must consider the tax ramifications associated with potential recharacterization of equity participation rights/loans as debt or equity. The tax laws remain unclear on the proper tax treatment of these equity kicker payments. The tax treatment of interest, dividends, rental income, and income effectively connected to a US business is also discussed.
Publication Name: Journal of Real Estate Taxation
Subject: Real estate industry
ISSN: 0093-5107
Year: 1997
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