Interest Deduction Limit under TCJA Under the Tax Cuts and Jobs Act of 2017 (TCJA), the deduction for interest paid or accrued to a related or unrelated party is limited to the sum of the taxpayer’s business interest income and 30% of adjusted taxable income for the year.   For taxable years before 2022, the limitation... Read More

One of the major drawbacks for foreign investors and foreign companies that invest in U.S. real estate is the withholding requirement associated with transactions covered by the Foreign Investment in Real Property Tax Act (FIRPTA). These investors do not have the luxury of waiting until Tax Day and filing a U.S. return with a check... Read More

We write a great deal about the transactions that are subject to taxation under the Foreign Investment in Real Property Tax Act (FIRPTA). But what about the transactions that are not subject to FIRPTA tax? Indeed, there are many. There are exemptions in the U.S. tax code that can allow a foreign investor or foreign... Read More