News & Analysis as of

Foreign Investment in Real Property Tax Act

Can Foreign Partners Now Exit Partnerships Tax Free?

by Bracewell LLP on

In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more

Sale of U.S. Operating Partnerships by Non-U.S. Persons May Not Generate ECI—U.S. Tax Court Declines to Follow Revenue Ruling...

by K&L Gates LLP on

In a recently published decision, the U.S. Tax Court declined to follow the longstanding position of the U.S. Internal Revenue Service (“IRS”), articulated in Revenue Ruling 91-32, that a non-U.S. partner’s gain or loss from...more

The Malta Pension Plan – A Supercharged, Cross-Border Roth IRA

by Bilzin Sumberg on

In the cross border setting, two of the principal goals in international tax planning are (i) deferral of income earned offshore and (ii) the tax efficient repatriation of foreign profits at low or zero tax rates in the...more

Grecian: Tax Court Rejects IRS Ruling - Five Things You Need to Know

On July 13, 2017, in Grecian Magnesite Mining, Industrial and Shipping Co. SA v. Commissioner (149 T.C. No. 3 (2017), the U.S. Tax Court concluded that gain recognized by a foreign corporation upon redemption of its interest...more

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

by Shearman & Sterling LLP on

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more

Trends in cross-border real estate investment and the changing tax landscape

by Hogan Lovells on

Real estate markets in both the U.S. and Europe continue to attract significant overseas investment. With interest rates at or near all-time lows, and dwindling returns in other asset classes, real estate has emerged as...more

2017 commercial real estate outlook: The impact of U.S. tax reform - April 2017

by Hogan Lovells on

Despite strengthening market headwinds and troubling political uncertainties, the U.S. commercial real estate market is likely to remain the top destination for global real estate capital in 2017, and may even see a return to...more

Tax Considerations For The Closely-Held Foreign Investor In U.S. Real Property – Part II

by Farrell Fritz, P.C. on

Aside from planning for the taxation of U.S.-sourced rental income, the foreigner must plan for the disposition of the USRP pursuant to a sale. The taxation of gain realized by a foreigner on the sale of an interest in...more

Brexit Will Cause Deal Flow Reduction

Britain's historic vote to exit the European Union has sent shock waves throughout the global economy and will certainly have economic and political repercussions for years. How will the vote impact U.S. real...more

Reforms to the Foreign Investment in Real Property Tax Act and REIT Taxation - Tax Update Volume 2016, Issue 1

by Pepper Hamilton LLP on

The reforms generally encourage foreign investment in U.S. real estate. The enacted Protecting Americans from Tax Hikes Act of 2015 (the Act) contains numerous reforms to the Foreign Investment in Real Property Tax Act...more

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

by Kelley Drye & Warren LLP on

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

"Key Takeaways: Changes Will Impact Investment in US Real Estate"

On May 4, 2016, Skadden presented the seminar “How FIRPTA and REIT Changes Will Impact Investment in US Real Estate.” Congressman Joseph Crowley, D-N.Y., gave the introductory remarks, and panelists included Jeffrey DeBoer,...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

USA FDI News - April 2016

by Williams Mullen on

USA FDI News highlights the FAQs arising from your projects - from how to finance a deal to selecting the right visa or tax strategy and more. We want to keep USA FDI News interactive and relevant to your international...more

The U.S. Treasury Releases New FIRPTA Regulations

by Locke Lord LLP on

On February 17, 2016, the U.S. Treasury released new regulations (the New FIRPTA Regulations) that reflect changes that the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) made to the Foreign Investment in Real...more

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

by Proskauer - Tax Talks on

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

PATH Act Creates New FIRPTA Withholding Tax Rate and Exemption for Foreign Pension Funds

by Dechert LLP on

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed into law on December 18, 2015, has resulted in a number of changes to the taxation of investments in U.S. real property by foreign investors. Among...more

Corporate E-Note - February 2016

by Burr & Forman on

With the start of the 2016 tax reporting season, taxpayers making certain payments to a person or entity with a Tennessee address may find that Tennessee has added to the number of information returns they need to...more

West Coast Real Estate Update: Feb. 2016 #4

by Holland & Knight LLP on

ASTM Updates Property Condition Assessments Standard - The American Society for Testing and Materials (ASTM) published at the end of 2015 the latest version of the Standard Guide for Property Condition Assessments:...more

New FIRPTA Regulations

by Charles (Chuck) Rubin on

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

PATH Act Implemented

On December 18, 2015, President Barack Obama signed the Protecting Americans from Tax Hikes Act of 2015, or the PATH Act, into law. Beginning on February 16, 2016, the PATH Act amends FIRPTA (the Foreign Investment in Real...more

New FIRPTA Exceptions Provide Opportunities for Foreign Pensions and Investment Funds

by Carlton Fields on

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

PATH Act Amends FIRPTA

Congress enacted the Foreign Investment in Real Property Tax Act (FIRPTA) in 1980 to impose U.S. income tax on certain foreign persons that invest in United States real property interests (USRPI). The FIRPTA tax is collected...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

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