U.S. Taxation of Foreign Investment in U.S. Real Estate (Portfolio 6540)
This Portfolio discusses the federal tax rules bearing upon foreign investment in U.S. real estate.
The Worksheets contain numerous sample documents which practitioners will find invaluable when assisting clients with tax issues in this area. The Worksheets are divided into the following categories: (1) materials relating to establishing that a corporation’s stock is not a U.S. real property interest; (2) materials relating to certification of non-foreign status; (3) materials relating to corporate distributions, nonrecognition exchanges, and reorganizations; and (4) materials relating to withholding certificates.
This Portfolio may be cited as Bracuti, Kaplan, and Plowgian, 6540 T.M., U.S. Taxation of Foreign Investment in U.S. Real Estate.
Table of Contents
II. Taxation of Current Income from U.S. Real Estate Investments
III. U.S. Income Taxation of Foreign Persons’ Disposition of U.S. Real Property Interests
IV. FIRPTA Withholding — §1445
V. U.S. Gift and Estate Tax Considerations