The Us Foreign Investment In Real Property Tax Act

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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.

International Direct Investment

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Author :
language : en
Publisher:
Release Date : 1984

International Direct Investment written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1984 with International finance categories.

Internal Revenue Bulletin

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Author : United States. Internal Revenue Service
language : en
Publisher:
Release Date : 1990

Internal Revenue Bulletin written by United States. Internal Revenue Service and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1990 with Tax administration and procedure categories.

International Applications Of U S Income Tax Law

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Author : Ernest R. Larkins
language : en
Publisher: John Wiley & Sons
Release Date : 2003-11-20

International Applications Of U S Income Tax Law written by Ernest R. Larkins and has been published by John Wiley & Sons this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003-11-20 with Business & Economics categories.

A clear, concise explanation of United States tax law’s international aspects In tackling a sometimes thorny set of laws and treaties, international tax expert Ernest Larkins emphasizes their economic effects, showing how to avoid hazards while reaping rewards which often go ignored. Coverage includes: Special issues arising when a foreign person invests in U.S. real estate, as well as the best structures for holding such real estate What a controlled foreign corporation is and what consequences result from this status Acceptable transfer pricing methods and what penalties apply when taxpayers do not follow arm’s-length principles International Applications of U.S. Income Tax Law also contains many useful tools which allow readers to build understanding through practice, as well as formulate and solve the complex problems international taxes can present. Order your copy today!

General Explanations Of The Administration S Fiscal Year 2014 Revenue Proposals

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Author : Treasury Department
language : en
Publisher: Government Printing Office
Release Date : 2013-05-07

General Explanations Of The Administration S Fiscal Year 2014 Revenue Proposals written by Treasury Department and has been published by Government Printing Office this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-05-07 with Political Science categories.

Each February when the President releases his proposed Federal Budget for the following year, Treasury releases the General Explanations of the Administration's Revenue Proposals. Known as the “Green Book” (or Greenbook), the document provides a concise explanation of each of the Administration’s Fiscal Year 2014 tax proposals for raising revenue for the Government. This annual document clearly recaps each proposed change, reviewing the provisions in the Current Law, outlining the Administration's Reasons for Change to the law, and explaining the Proposal for the new law. Ideal for anyone wanting a clear summary of the Administration's policies and proposed tax law changes. While many of the proposals included in the FY 2014 budget are either the same or modified versions of proposals included in the Administration’s FY 2013 budget, there are nearly 50 new revenue proposals in the 2014 budget, including closing loopholes and changing tax credits and incentives. Following are a few of the President's new revenue proposals that are explained in the Treasury FY2014 Green Book: Extending employment tax credits for hiring veterans; Requiring derivatives contracts to be marked to market and taxed as ordinary income on an annual basis; Repealing the domestic manufacturing deduction for oil and natural gas production; Establishing multiple incentives for investment in infrastructure, including “America Fast Forward” Bonds and increasing caps on other bonds; Taxing carried interest as ordinary income; Returning the estate tax to 2009 levels, modifying the recent estate tax exclusions and rates signed into law earlier this year under the American Taxpayer Relief Act; Prohibiting individuals from accumulating more than $3 million in tax-preferred retirement accounts; and Capping the benefit of certain deductions (such as a charitable contribution deduction) to 28 percent for taxpayers at or above the 33% marginal tax rate.

Joint Committee On Taxation S General Explanation Of Tax Legislation Enacted In The 109th Congress

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Author : Joint Committee on Taxation
language : en
Publisher: CCH
Release Date : 2007

Joint Committee On Taxation S General Explanation Of Tax Legislation Enacted In The 109th Congress written by Joint Committee on Taxation and has been published by CCH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Business & Economics categories.

This Blue Book prepared by the staff of the Joint Committee on taxation in consultation with the staffs of the House Committee on Ways and Means and the Senate Committee on Finance, provides an explanation of tax legislation enacted in the 108th Congress. Officially titled, General Explanation of Tax Legislation Enacted in the 108th Congress (JCS-5-05), it is prepared so lawmakers, tax practitioners and other interested parties have explanations in one volume of the final tax legislation enacted during the 108th Congress.

Internal Revenue Cumulative Bulletin

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Author : United States. Internal Revenue Service
language : en
Publisher:
Release Date : 1992

Internal Revenue Cumulative Bulletin written by United States. Internal Revenue Service and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1992 with Tax administration and procedure categories.

Explanation Of Proposed Income Tax Treaty Between The United States And Canada

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Author :
language : en
Publisher:
Release Date : 1981

Explanation Of Proposed Income Tax Treaty Between The United States And Canada written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1981 with Double taxation categories.

Taxation Of Individuals Who Renounce Their U S Citizenship

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Author : United States. Congress. Senate. Committee on Finance
language : en
Publisher:
Release Date : 1996

Taxation Of Individuals Who Renounce Their U S Citizenship written by United States. Congress. Senate. Committee on Finance and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1996 with Business & Economics categories.

96th Congress Legislative Record Of The Committee On Ways And Means U S House Of Representatives Along With Brief Historical And Other Pertinent Information Concerning The Committee

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Author : United States. Congress. House. Committee on Ways and Means
language : en
Publisher:
Release Date : 1981

96th Congress Legislative Record Of The Committee On Ways And Means U S House Of Representatives Along With Brief Historical And Other Pertinent Information Concerning The Committee written by United States. Congress. House. Committee on Ways and Means and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1981 with Finance, Public categories.