International Trade Tax Residential Real Estate

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U.S. Tax Structures Utilized In Connection With Foreign Investment In U.S. Real Estate

U.S. real estate is expected to attract a record amount of foreign investment in 2016. The U.S. real estate market is perceived as a safe haven in light of economic uncertainty in China, the refugee crisis in Europe and the...more

"FIRPTA Reform Impacts Investment Opportunities in US Real Estate"

In recent months, much has been written to describe the reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) contained in the Protecting Americans From Tax Hikes Act of 2015 (the Act), which have been...more

Plan Ahead to Avoid or Minimize US Estate Tax

If you are not a US resident or a US citizen and are considering buying assets in the US, there are ways to avoid or minimize US estate tax on those assets. ...more

UK Budget 2016 – Key Tax Measures

The Chancellor of the Exchequer delivered the UK Budget for 2016 on 16 March 2016. The Budget was delivered against the backdrop of international tax developments, relating to the Organisation for Economic Co-operation and...more

Real Estate Update: Australia's foreign investment regime reloaded and recent developments

On 22 February 2016, the Australian Federal Government announced the introduction of various tax compliance obligations that are to be included as conditions of future Foreign Investment Review Board (FIRB)...more

Real Estate Investments by Qualified Foreign Pension Funds After the PATH Act

The Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) included a number of significant changes to the U.S. federal income tax rules related to real estate investment trusts (“REITs”) and investments by non-U.S....more

Real Property and Equities Transactions: Withholding is Now the First Port of Call

At present, capital gains and capital losses made by foreign residents are disregarded unless the asset being disposed of is taxable Australian real property (TARP). To ensure that foreign residents actually pay tax on...more

New FIRPTA Regulations

As previously noted, the Protecting Americans from Tax Hikes Act of 2015 modify the withholding provisions under FIRPTA. The Service has now issued regulations implementing the statutory changes. ...more

New FIRPTA Exceptions Provide Opportunities for Foreign Pensions and Investment Funds

The Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) authorized the United States to tax foreign persons on the gain from the disposition of U.S. real property or U.S. real property interests (USRPIs). Recently,...more

FIRPTA Tax Withholding Set to Increase Effective February 16, 2016

Beginning on February 16 of this year, the rate of tax withholding required by the Foreign Investment in Real Property Tax Act (FIRPTA) will increase from 10% to 15%. FIRPTA imposes federal tax on the sale of an interest in...more

Withholding Tax Set to Increase

The Foreign Investment in Real Property Tax Act (FIRPTA) subjects foreign sellers to U.S. tax when they sell their interest in real property located in the U.S., including interests in companies that predominately hold real...more

Disclose of Cash Real Estate Purchases

The purchase of real estate without bank financing presents an opportunity for those with unclean funds to launder those funds and make them appear legitimate, at least in the opinion of the Financial Crimes Enforcement...more

PATH Act Changes to FIRPTA

The Protecting Americans from Tax Hikes Act of 2015 (the PATH Act, Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) made some important changes to the U.S. federal income tax...more

PATH Act Changes to FIRPTA

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act,” Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) made some important changes to the U.S. federal income tax...more

U.S. Treasury Seeks to Stanch Flow of Proceeds of Corruption and Other Crimes Into Manhattan and Miami Luxury Real Estate

On January 13, 2016, the U.S. Treasury’s financial intelligence unit, known as the Financial Crimes Enforcement Network (FinCEN), announced the issuance of geographic targeting orders (GTOs) to certain unnamed real estate...more

International Tax Advisory: New Law Brings Some Welcome FIRPTA Changes

On December 18, President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Despite the new law’s name, a number of its provisions affect foreign investors. The PATH Act introduces several...more

PATH Act Presents Opportunities for Tax-Efficient Non-U.S. Investment in U.S. Real Estate

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Among its numerous revisions to federal tax law, the PATH Act significantly amended various...more

New PATH Act Modifies Tax Rules Applicable to Foreign Investment in U.S. Real Estate and Introduces a New Exemption for Certain...

On December 18, 2015, as part of the “Protecting Americans from Tax Hikes of 2015” (the “PATH Act”), President Obama signed into law provisions that make significant changes to the so-called FIRPTA rules that govern the U.S. ...more

Consolidated Appropriations Act Impacts REITs, FIRPTA Requirements and Depreciation

The recently enacted Consolidated Appropriations Act, 2016 makes some significant changes that affect real estate investment trusts, Foreign Investment in Real Property Tax Act reporting and withholding requirements, and...more

Protecting Americans from Tax Hikes Act Makes Substantial Changes to Tax Law

The Protecting Americans from Tax Hikes Act of 2015 (PATH Act) was signed into law on Dec. 18, 2015, as part of the Consolidated Appropriations Act, 2016. The PATH Act alters the regime for taxing foreign persons holding U.S....more

The PATH Act

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act). - extends or makes permanent a number of temporary tax provisions that had expired or were set to...more

FIRPTA Withholding Rate Bumped Up To 15%

The Protecting Americans from Tax Hikes Act of 2015 was recently signed into law. Section 324 of the Act modifies Code Section 1445 to increase the required withholding amount on dispositions by nonresident aliens and foreign...more

Protecting Americans from Tax Hikes Act of 2015 Approved by Congress and Signed by the President

President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired...more

Congress Passes New Tax Laws Affecting REITs - Protecting Americans from Tax Hikes Act of 2015

On December 18, President Obama signed the Protecting Americans from Tax Hikes (PATH) Act of 2015 (the “Act”) into law. The Act provides for a number of favorable and flexible REIT-specific tax provisions, and implements...more

"New FIRPTA Reform: The Long-Awaited Game Changer for US Real Estate"

On December 18, 2015, President Obama signed into law a bill that will significantly reform the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). The Protecting Americans from Tax Hikes Act of 2015 (the Bill) will...more

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