Structuring Investments by Foreign Persons in U.S. Real Estate

5 Pages Posted: 10 Jul 2015

Date Written: May 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.

Suggested Citation

Appel, Alan, Structuring Investments by Foreign Persons in U.S. Real Estate (May 1, 2012). Journal of Taxation and Regulation of Financial Institutions, Vol. 25, No. 55, 2012, Available at SSRN: https://ssrn.com/abstract=2628212

Alan Appel (Contact Author)

New York Law School ( email )

185 West Broadway
New York, NY 10013
United States

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