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Corporate Taxes › Foreign Investment in Real Property Tax Act › Capital Gains

Freeman Law

Effectively Connected Income

Freeman Law on

Effectively Connected Income - Unlike FDAP income, the United States taxes effectively connected income (“ECI”) on a net basis. Effectively connected income is income that is effectively connected with the conduct of a U.S....more

A&O Shearman

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

A&O Shearman 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

Skadden, Arps, Slate, Meagher & Flom LLP

"Extenders Bill Makes Important REIT Reforms and Closes Door on REIT Spinoffs"

Skadden, Arps, Slate, Meagher & Flom LLP on

President Obama signed into law a bill that will significantly reform the taxation of real estate investment trusts (REITs). Most notably, the Protecting Americans from Tax Hikes Act of 2015 (the Bill) prevents companies from...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Senate Finance Committee Takes Unanimous Step Toward FIRPTA Reform"

Skadden, Arps, Slate, Meagher & Flom LLP on

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

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