The Treasury issued new final, temporary and proposed regulations that take aim at, and significantly reduce the effectiveness of, leveraged partnership structures intended to achieve tax deferral to the contributing partner....more
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