Document Type

Article

Publication Date

5-1-2012

Abstract

This article describes the basic principles of U.S. federal income tax liability under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) and the withholding mechanism that ensures collection of the tax. In addition, it sets forth some structuring alternatives to limit a foreign investor's tax exposure with respect to the ownership and subsequent disposition of U.S. real estate.

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