Transactions Beyond the Reach of FIRPTA Tax

  |  March 8, 2018

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

Understanding FIRPTA Tax, and Tax Treaties

  |  February 17, 2018

Did you know that foreign corporations can elect to be treated as a domestic corporation by the U.S. Internal Revenue Service (IRS) for tax purposes? It has advantages and disadvantages. Savvy investors will weigh the pros and cons. Foreign corporations are subject to taxation and withholding under the Foreign Investment in Real Property Tax Act... Read More

How Does FIRPTA Treat Distributions and Other Transactions by Property Investment Companies?

  |  February 2, 2018

FIRPTA taxes apply when foreign investors or property investment companies sell U.S. real estate assets. But what about distributions, liquidations and other transactions? A complicated system of FIRPTA rules apply to these situations and it is important to understand how these rules apply before structuring transactions. We’ll discuss some of the more common cases. Generally... Read More