Foreign Investment in Real Property Tax Act

News & Analysis as of

Global Tax News - February 2016

The European Commission has released its highly anticipated anti-tax-avoidance package. The package, released January 28, 2016, contains proposed rules and recommendations to avoid aggressive tax planning within the...more

FIRPTA reform under the Protecting Americans from Tax Hikes Act of 2015: key points for non-US investors

Among the reforms and provisions in the Protecting Americans From Tax Hikes Act of 2015 are several important changes to the Foreign Investment in Real Property Tax Act of 1980 (commonly referred to as FIRPTA) that are...more

PATH Act Brings FIRPTA Changes

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed December 18, 2015, introduces significant changes to the Foreign Investment in Real Property Tax Act (FIRPTA), particularly concerning REITs. ...more

MoFo Tax Talk - Volume 8, No. 4

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

Significant Changes to U.S. Taxation of REITs and Investments by Non-U.S. Investors in Real Property under the PATH Act

On December 18, 2015, President Obama signed into law an omnibus appropriations bill which included the Protecting Americans from Tax Hikes Act of 2015 (the "Act"). In addition to extending or making permanent a number of...more

New FIRPTA Reform Creates PATH to Potential Benefits for Existing REITs and Foreign Investors in the United States

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Among other changes, the PATH Act significantly modifies provisions of the Internal Revenue Code of...more

Changes To FIRPTA Affecting Real Estate Transactions

The Foreign Investment in Real Property Tax Act ("FIRPTA") is applicable to all transactions involving interests in real property where the Seller is a "foreign person" (this includes entities). According to the IRS, FIRPTA...more

Focus on Tax Strategies & Developments - January 2016

Protecting Americans from Tax Hikes Act of 2015—the Year-End Legislation f/k/a Extenders - Just in time for Christmas, Congress passed, with bipartisan support, and the President signed, the “Protecting Americans from...more

New FIRPTA Changes Provide Significant Opportunities, But No Panacea for Encouraging Non-U.S. Investment in U.S. Real Estate

Under FIRPTA, a non-U.S. person’s gain from the sale of U.S. real property interests is treated as income that is effectively connected with a U.S. trade or business (“ECI”), and therefore, is subject to U.S. federal income...more

Banking & Financial Services E-Note - January 2016

In Deutsche Bank Nat’l Trust Co. v. Estrella Perez, et al., No. 3D15-58, 2015 WL 8347002 (Fla. 3d DCA Dec. 9, 2015), Florida’s Third District Court of Appeal held that the trial court erred in dismissing a foreclosure case on...more

FIRPTA Withholding Amounts Change

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (PATH Act) as part of the Consolidated Appropriations Act, 2016. The new PATH Act reforms the Foreign Investment in...more

FIRPTA Withholding Tax Rate to Increase 15 Percent on February 2016

On December 18, 2015, the Protecting Americans from Tax Hikes Act (the Act) was signed into law. Among other items, the Act materially amends the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) to increase the...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

"Important FIRPTA and REIT Reforms Enacted"

The newly signed Protecting Americans from Tax Hikes Act of 2015 (the Act) includes several reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) and the taxation of real estate investment trusts...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

West Coast Real Estate Update: Jan. 2016 #2

California Senate Proposes $2 Billion on Housing for Homeless - California state senators put forth a proposal on Jan. 4, 2016, to spend $2 billion to build or rehabilitate permanent housing for homeless people,...more

Highlights of Substantial Tax Changes in the Consolidated Appropriations Act, 2016

Expiring tax provisions and “extenders” legislation have become fairly common in recent years. The typical pattern involves institution of one- or two-year provisions (short-lived due to revenue issues) that have expired with...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

Significant Changes Affecting REITs in The Protecting Americans from Tax Hikes Act of 2015

On December 18, 2015, President Obama signed into law the Consolidated Appropriations Act, 2016, an omnibus spending bill, with a division referred to as the Protecting Americans From Tax Hikes Act of 2015 (the “Act”), which...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

Tax Considerations in Real Estate Dispositions

In a typical real estate transaction, the seller deeds the real property to the buyer. This transaction is simple and straightforward for both buyer and seller. Although it is simple, is it the best structure from a tax...more

Alert: PATH Act Gives Tax Benefits to Emerging Growth Companies and Investors

On December 18, 2015, as part of passing an omnibus spending bill for fiscal year 2016, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the "PATH Act"). The PATH Act extends, in some cases...more

New PATH Act Changes Rules for Foreign Investment in US Real Estate and for REITs

The PATH Act exempts certain foreign pension funds from taxation under FIRPTA and significantly modifies the tax rules applicable to REITs. On December 18, 2015 (Enactment Date), US President Barack Obama signed the...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

67 Results
|
View per page
Page: of 3

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×