This course will discuss the critical tax and ownership structuring issues surrounding the purchase/ownership of U.S. real property by non-U.S. persons. It will discuss the various ownership structuring options that non-U.S. persons can utilize when purchasing U.S. real property and the income tax/estate tax consequence of each. It will further touch upon the income tax issues upon the ultimate sale of the U.S. real property and the application of the Foreign Investment in Real Property Tax Act - FIRPTA – and the withholding mechanism and reporting obligations required by that law.
Objectives:
Determine what is actually is a “U.S. real property interest”
Understand the advantages and disadvantages of U.S. real property investment structures and the income tax/estate tax consequences of each
Understand the impact and reporting requirements of FIRPTA upon the sale of the U.S. real property
Rita leads Wolf’s International Tax Practice, where she focuses on tax planning and compliance for international holdings. Rita has extensive experience advising clients on the tax aspects of cross-border business activities, structuring...
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