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FIRPTA taxes apply when foreign investors or property investment companies sell U.S. real estate assets. But what about distributions, liquidations and other transactions? A complicated system of FIRPTA rules apply to these situations and it is important to understand how these rules apply before structuring transactions. We’ll discuss some of the more common cases. Generally…
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Let’s say a foreign corporation owns a building in the United States that houses a restaurant. Suppose the corporation owns everything, including the land, the building and the furnishings. If the company sells the entire asset, would it pay taxes on the furniture, all those tables, chairs and barstools? Questions like this—we’ll answer it later—make…
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Under the pending legislation in Congress, the House of Representatives has passed legislation to reduce the corporate income tax rate from 35% to 20% effective January 1, 2018. The Senate tax bill reduces the corporate income tax rate from 35% to 20% but the effective date is one full year later on January 1, 2019. For…
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Those looking for Congress to pass lots of foreign investment tax legislation in the next year will likely be disappointed. But the tax reform effort that Republicans are currently brewing in Washington, while not aimed squarely at foreign investors, could have a huge impact. Tax reform could be very beneficial for non-U.S. investors, particularly those…
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Historically, U.S. real estate has been a solid investment for non-U.S. persons, both as a diversification strategy and for pure returns. But the tax consequences can be severe if not structured properly. Investment in U.S. Real Estate by a non-U.S. person can lead to rates north of 50 percent for those who do not plan…
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