Foreign Investment in Real Property Tax Act

News & Analysis as of

Nowotny on Private Placement Group Variable Deferred Annuity Contracts for Tax Exempt and Foreign Investors [Video]

The Private Placement Group Variable Deferred Annuity Contract aka GAC has quietely been used by tax-exempt organizations for some time. As far as I can count, $50 billion of tax exempt transactions have utilized the GAC as a...more

Storm clouds on the horizon. . . foreign real estate investments in secondary US markets

Commercial real estate assets in major markets such as New York City, Washington, DC, Boston, Chicago, Los Angeles and San Francisco have experienced a strong rebound in values and are being transacted near, or above, their...more

The House Joins the Senate Finance Committee in Proposing FIRPTA Reform

FIRPTA real estate tax reform continues its momentum with the recent release of bill text for H.R. 2128, the latest House bill introduced by Kevin Brady (R-Texas) and J Crowley (D-NY). In connection with the filing of the...more

Locke Lord QuickStudy: Tax Code Amendments Proposed to Facilitate Foreign Investment in REITs and U.S. Commercial Properties

On April 30, 2015, Representatives Kevin Brady (R-TX) and Joe Crowley (D-NY), both members of the U.S. House Ways & Means Committee, introduced legislation intended to encourage foreign investment in United States real...more

FIRPTA Changes Coming?

It is a pleasure to see something coming out of Congress these days that seeks to attract foreign investment, instead of repelling it. A recent bill by Representatives Brady and Crowley seeks to modernize FIRPTA by expanding...more

Tax Policy Update

NUMBER OF THE WEEK: 1,462. The total number of comments received by the Senate Finance Committee’s five bipartisan tax reform working groups in response to the committee’s request for public input on overhauling the nation’s...more

New REIT Bill Coming?

In late April, Senator Orrin Hatch introduced Senate bill 915, the Real Estate Investment and Jobs Act of 2015. When a foreign person invests in property in the U.S., that person is subject to U.S. tax when he/she/it...more

"FIRPTA Reform Opens Door to Increased Foreign Investment in US Real Estate"

This afternoon, Reps. Kevin Brady (R-Texas) and Joseph Crowley (D-N.Y.) re-introduced in the House of Representatives a bill to significantly reform the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R....more

New Russian CFC Rules Will Impact Inbound U.S. Tax Planning

According to recent estimates, the number of wealthy Russians investing in the United States ballooned in 2014 as a result of political turmoil and a disintegrating ruble causing Russians to seek a safe haven for their wealth...more

"Senate Finance Committee Takes Unanimous Step Toward FIRPTA Reform"

On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more

Foreign Investment In The U.S. Through Romania Just Became More Interesting

All “modern” income tax treaties concluded by the United States contain a “Limitation on Benefits” (LOB) provision. The purpose of such a provision is to prevent “treaty shopping.” Romania is one of the few remaining...more

Comprehensive Tax Reform Remains a Top Priority for Key Members

Congressional Consideration Continues, Including Provisions That Would Impact the Real Estate Industry - The House Ways & Means Committee is currently holding Member-level discussions on tax reform and is in the...more

Foreign Investors In REITs: Opportunities Under FIRPTA Reform Proposals

Real estate investment trusts (REITs) have long been a tax-efficient vehicle for foreign persons seeking to invest in U.S. real estate. Now, two legislative proposals titled the Real Estate Investment and Jobs Act of 20131...more

Proposed FIRPTA Changes Would Attract More Foreign Investment In U.S. Real Estate

Non-U.S. taxpayers are generally exempt from U.S. federal income tax on gain from the sale of U.S.-situs capital assets. The one major exception is U.S. real estate. Under the Foreign Investment in U.S. Real Property Tax...more

Tax Planning Important For Foreign Purchasers Of U.S. Real Estate

It is no secret that the South Florida real estate market has been a buying opportunity for wealthy foreigners, in light of the decline in U.S. home prices and the lower value of the U.S. dollar against some foreign...more

"New FIRPTA Reform Would Attract Foreign Investment in US REITs"

Yesterday, Reps. Kevin Brady of Texas and Joseph Crowley of New York proposed a major reform to the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R. 2870, the Real Estate Investment and Jobs Act of...more

Seeing the Forest through the Trees -- A New Method for Structuring Investment by Foreign Investors in U.S. Timber and...

Overview - Large institutional investors including pension plans and endowments and foundations have made significant investments in timberland over the last forty years. These same investors have also made significant...more

Ropes & Gray’s Private Investment Fund Update: June 2013

Highlights - SEC Updates Form PF "Frequently Asked Questions" - The SEC recently released updated "Frequently Asked Questions" relating to Form PF that, among other things, clarified how Form PF filers should...more

Jeffrey DeBoer on the intersection of Washington and commercial real estate [Video]

John Corey, Founding Partner of Greentarget, interviews Jeffrey De Boer, President and Chief Executive Officer of The Real Estate Roundtable, on the intersection of Washington and commercial real estate....more

Proposed 2014 Budget Encourages Private Investment in Infrastructure

This week, the Obama administration released its proposed budget for the 2014 fiscal year. Notably, the budget encourages private investment in infrastructure projects through various liberalizations of the tax laws relating...more

Tax Kung Fu – Tax Structuring for Chinese Investment in U.S. Real Estate

Overview - Unless you have been traveling the galaxies for the last twenty years, you haven’t missed the “Chinese Miracle”. Its enormous impact is felt globally. When you see the skyline of Shanghai, the new meaning of...more

American Taxpayer Relief Act of 2012 Approved by Congress and Signed by the President

Summary - President Obama on January 2, 2013 signed into law the American Taxpayer Relief Act of 2012 (the “Act”). The Act extends certain tax rates, tax credits, and other provisions previously enacted by other tax...more

Fiscal Cliff Tax Changes

On New Year’s Day 2013, the “American Taxpayer Relief Act of 2012” (the Act) was enacted to avoid the impact of automatic “fiscal cliff” tax increases. The Act, effective January 1, 2013, retains and makes permanent the...more

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