Foreign Investors Real Property Tax Act: Historical Perspective and Critical Evaluation

Abstract:     
This Article first discusses the United States tax treatment of foreigners generally and the pre-Foreign Investors Real Property Tax Act withholding and taxation scheme with respect to foreign investment in United States real estate. Then follows a discussion of the several ways in which foreign investors were, before the Act, able to avoid tax on the disposition of United States real estate and a critical evaluation of the Act's response to those avoidance methods. Finally, a discussion of the Act's enforcement provisions and a general discussion of withholding of tax on nonresidents is provided.

Number of Pages in PDF File: 41

Keywords: Foreign Investors Real Property Tax Act, foreign investment, United States real estate, taxes, tax law, property law and real estate

Accepted Paper Series