Structuring Investments by Foreign Persons in U.S. Real Estate
5 Pages Posted: 10 Jul 2015
Date Written: May 1, 2012
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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