Repeal of Foreign Investment in Real Property Tax Act - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Repeal of Foreign Investment in Real Property Tax Act write by United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation. This book was released on 1984. Repeal of Foreign Investment in Real Property Tax Act available in PDF, EPUB and Kindle.
Repeal of Foreign Investment in Real Property Tax Act
Repeal of Foreign Investment in Real Property Tax Act - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Repeal of Foreign Investment in Real Property Tax Act write by United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation. This book was released on 1984. Repeal of Foreign Investment in Real Property Tax Act available in PDF, EPUB and Kindle.
Suppose FIRPTA Was Repealed
Suppose FIRPTA Was Repealed - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Suppose FIRPTA Was Repealed write by Willard B. Taylor. This book was released on 2013. Suppose FIRPTA Was Repealed available in PDF, EPUB and Kindle. This article argues, as others have before, that the Foreign Investment in Real Property Tax Act of 1980 (or “FIRPTA”), or at least the provisions of FIRPTA relating to “United States real property holding corporations,” should be repealed. Their enactment in 1980 was misguided and in any event changes in the Internal Revenue Code since then have made the provisions obsolete. But if FIRPTA is repealed, in whole or in part, the article argues that the lack of parity between foreign investment in real property that is made directly or through a partnership, on the one hand, and foreign investment in a real estate investment trust (or a regulated investment company that invests in shares of real estate investment trusts) should be dealt with. Otherwise, repeal will exacerbate existing distortions (which were already pushed further by FIRPTA) resulting from the choice of the entity used to make an investment in US real property. The article also suggests that repeal of FIRPTA would provide an opportunity to look at the taxation of foreign investment in the United States more broadly and in particular the rules that tax income from U.S. real property. The tax treatment of inward investment is a generally neglected subject.The article concludes by arguing against legislation that would keep the FIRPTA rules and simply expand provisions of present law that favor foreign investment through real estate investment trusts, such as the Real Estate Jobs and Investment Act of 2011.
The US Foreign Investment in Real Property Tax Act
The US Foreign Investment in Real Property Tax Act - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook The US Foreign Investment in Real Property Tax Act write by Angela W. Yu. This book was released on 2017-10-24. The US Foreign Investment in Real Property Tax Act available in PDF, EPUB and Kindle. U.S. real estate is enormously attractive to many foreign investors, who are thus ushered into the ambit of the complex U.S. Foreign Investment in Real Property Tax Act (FIRPTA). A full understanding of the associated tax implications on the part of these investors and their advisors is essential if they are to implement the correct structure to maximize their returns, avoid unnecessary withholding, and comply with applicable requirements. This book, the first practical guide to FIRPTA, clearly articulates the operation and transactional implications of FIRPTA and its interaction with various other regimes, sets forth real life situations, and points out potential traps, all in a readily graspable format. Among the tax issues and consequences that directly or indirectly affect foreign investors in U.S. real property interests, the author highlights the following and more: • the real estate investment trust (REIT); • withholding taxes that are jointly and severally liable for buyers and sellers; • treatment of rental, interest, and dividend income; • effect of the branch profits tax; • tax treaty benefits; • exemptions to FIRPTA; • special rules applicable to foreign governmental investors; • tax reporting standards and potential penalties for noncompliance; and • state and local tax issues relating to U.S. real estate investments. Providing a straightforward and accessible guide for navigating the tax issues that confront foreign investors in U.S. real estate, this resource will prove invaluable in identifying and formulating the correct strategies for investors and their advisors with respect to investments in the U.S. real estate market. It is sure to benefit all interested parties for years to come. Angela W. Yu, a tax partner of KPMG’s New York office, has extensive experience providing integrated tax advice to clients on cross-border transactions. She is a frequent speaker on U.S. tax issues, and has addressed many professional organizations.
Description of S. 1915 Relating to Tax Treatment of Foreign Investment in U.S. Real Property
Description of S. 1915 Relating to Tax Treatment of Foreign Investment in U.S. Real Property - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Description of S. 1915 Relating to Tax Treatment of Foreign Investment in U.S. Real Property write by United States. Congress. Joint Committee on Taxation. This book was released on 1984. Description of S. 1915 Relating to Tax Treatment of Foreign Investment in U.S. Real Property available in PDF, EPUB and Kindle.
