Tax Effective Structuring Of Foreign Investment In Us Real Estate
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Tax Effective Structuring Of Foreign Investment In Us Real Estate
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Author : Stephen A. Nauheim
language : en
Publisher: I B C Financial Publishing
Release Date : 1991-01-01
Tax Effective Structuring Of Foreign Investment In Us Real Estate written by Stephen A. Nauheim and has been published by I B C Financial Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 1991-01-01 with Commercial law categories.
Structuring Foreign Investments In U S Real Estate
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Author :
language : en
Publisher:
Release Date :
Structuring Foreign Investments In U S Real Estate written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on with Estate planning categories.
The Us Foreign Investment In Real Property Tax Act
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Author : Angela W. Yu
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2017-10-24
The Us Foreign Investment In Real Property Tax Act written by Angela W. Yu and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-10-24 with Law categories.
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.
Structuring Foreign Investment In U S Real Estate
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Author : W. Donald Knight
language : en
Publisher:
Release Date : 1982
Structuring Foreign Investment In U S Real Estate written by W. Donald Knight and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1982 with Estate planning categories.
Taxation Of Foreign Investment In U S Real Estate
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Author : Department of the Treasury
language : en
Publisher: Forgotten Books
Release Date : 2015-06-14
Taxation Of Foreign Investment In U S Real Estate written by Department of the Treasury and has been published by Forgotten Books this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-06-14 with Business & Economics categories.
Excerpt from Taxation of Foreign Investment in U. S. Real Estate Dear Mr. Chairman: Section 553 of Public Law No. 95-500, the "Revenue Act of 1978," required the Treasury Department to conduct a study and analysis of the appropriate tax treatment of income from, or gain on the sale of, interest in United States property held by nonresident aliens and foreign corporations. The Secretary is required to transmit a report of the results of this study, together with the recommendations of the Department, within six months of the date of enactment of the Act. Pursuant to these provisions, I hereby submit a report entitled "Taxation of Foreign Investment in U.S. Real Estate." Under present law, capital gains realized by nonresident aliens and foreign corporations are not subject to U.S. tax unless they are "effectively connected" with a U.S. trade or business. The Treasury Report finds that, while most real property holdings of foreign person is used in a U.S. trade or business, foreign persons rarely incur capital gains tax on the disposition of their U.S. property holdings. The Report identifies various ways in which the capital gains on real estate, which would ordinarily be taxable, can be converted into capital gain on some other asset, which would not. The principal means by which this is accomplished is through a real property holding company and converting gain realized on disposition of the "effectively connected" property into gain realized on disposition of the shares, which is not deemed "effectively connected." The Treasury does not believe that taxing capital gain on the sale of corporate shares is desirable or practical. But to prevent unintended tax avoidance, the Treasury recommends modifying certain specific statutory provisions under which foreign taxpayers convert taxable gain on real estate into nontaxable gain. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.
Taxation Of Foreign Investment In U S Real Estate
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Author : United States. Department of the Treasury
language : en
Publisher:
Release Date : 1979
Taxation Of Foreign Investment In U S Real Estate written by United States. Department of the Treasury and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1979 with Aliens categories.
Foreign Investment In U S Real Estate
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Author :
language : en
Publisher: Section of Real Property Probate & Trust Law
Release Date : 1990
Foreign Investment In U S Real Estate written by and has been published by Section of Real Property Probate & Trust Law this book supported file pdf, txt, epub, kindle and other format this book has been release on 1990 with Investments, Foreign categories.
Tax Planning For Foreign Investors In The United States
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Author : Adam Starchild
language : en
Publisher: Springer Science & Business Media
Release Date : 2013-06-29
Tax Planning For Foreign Investors In The United States written by Adam Starchild and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-06-29 with Business & Economics categories.
If you arenot a citizen or resident of the United States (U.S.) and you are contemplating either making or expanding an investment in the U .S., either for yourself as an individual or for a business, you arenot alone. The U.S. is the country of first choice for many foreign investors. This is due to the fact that the U.S. offers foreign investors many advantages, some ofwhich are in short supply in today's world. The primary advantage that the U.S. affords foreign investorsisthat it endorses the economic concept of free enterprise. While it is true that the Federal and state governments have interfered with the private economy to some extent, the prevailing economic philosophy in the U .S. remains laissez faire. History has taught the U.S. that the market place allocates the finite resources of a country betterthan the government, and the advantagesoftbis philosophy have not been overlooked by foreign investors. Another attractive feature of the U .S. as an investment site is its political stability. The present form of constitutional government has presided for over 200 years, and this history provides foreign investors with a measure of security which is absent elsewhere.
Description Of S 1915 Relating To Tax Treatment Of Foreign Investment In U S Real Property
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Author : United States. Congress. Joint Committee on Taxation
language : en
Publisher:
Release Date : 1984
Description Of S 1915 Relating To Tax Treatment Of Foreign Investment In U S Real Property written by United States. Congress. Joint Committee on Taxation and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1984 with Capital gains tax categories.
Structuring Foreign Investments In U S Real Estate
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Author : W. Donald Knight
language : en
Publisher:
Release Date : 1982
Structuring Foreign Investments In U S Real Estate written by W. Donald Knight and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1982 with Estate planning categories.