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FIRPTA Investors Face Important Choices Under New Partnership Tax Audit Rules

Beginning in tax year 2018, IRS partnership tax audit adjustments will be assessed at the partnership level, not the partner level, and the partnership will owe the tax, penalties and interest.

Why IRS requires 25% foreign owned blocker to file IRS Form 5472

Purpose of Form 5472 In transactions between unrelated third parties, the prices charged between the parties is controlled by market forces.   However, with transactions between related parties, there is no corresponding conflict of interest between the parties to ensure that market prices are used. The IRS developed Form 5472 to collect information and identify potential…

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Foreign Real Estate Investors Must Consider All US Taxes

By Brad Wagner, CPA. Wagner, Kaplan, Duys, & Wood, LLP, Bethesda, Maryland Foreign inbound investors in U.S. real estate anticipate owing Federal income tax on the profits from the rental and sale of their properties. However, many do not realize that there are state and local taxes that will be incurred. This is because, many foreign…

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TCJA Will Affect Foreign Investments In US Real Estate

In December 2017, Congress passed the Tax Cuts and Jobs Act (“TCJA”) and the President signed it into law on December 22, 2017. The tax act has made significant changes that affect foreign investors in United States real estate (“FIRPTA”) utilizing the blocker corporation structure.

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