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Repeal Of Foreign Investment In Real Property Tax Act
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Author :United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation Publisher : ISBN 13 : Total Pages :178 pages Book Rating :4.F/5 ( download)
Book Synopsis Repeal of Foreign Investment in Real Property Tax Act by : United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation
Download or read book Repeal of Foreign Investment in Real Property Tax Act written by United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation and published by . This book was released on 1984 with total page 178 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation Publisher : ISBN 13 : Total Pages :0 pages Book Rating :4.:/5 (16 download)
Book Synopsis Repeal of Foreign Investment in Real Property Tax Act by : United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation
Download or read book Repeal of Foreign Investment in Real Property Tax Act written by United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation and published by . This book was released on 1984 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Suppose FIRPTA Was Repealed by : Willard B. Taylor
Download or read book Suppose FIRPTA Was Repealed written by Willard B. Taylor and published by . This book was released on 2013 with total page 49 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article argues, as others have before, that the Foreign Investment in Real Property Tax Act of 1980 (or “FIRPTA”), or at least the provisions of FIRPTA relating to “United States real property holding corporations,” should be repealed. Their enactment in 1980 was misguided and in any event changes in the Internal Revenue Code since then have made the provisions obsolete. But if FIRPTA is repealed, in whole or in part, the article argues that the lack of parity between foreign investment in real property that is made directly or through a partnership, on the one hand, and foreign investment in a real estate investment trust (or a regulated investment company that invests in shares of real estate investment trusts) should be dealt with. Otherwise, repeal will exacerbate existing distortions (which were already pushed further by FIRPTA) resulting from the choice of the entity used to make an investment in US real property. The article also suggests that repeal of FIRPTA would provide an opportunity to look at the taxation of foreign investment in the United States more broadly and in particular the rules that tax income from U.S. real property. The tax treatment of inward investment is a generally neglected subject.The article concludes by arguing against legislation that would keep the FIRPTA rules and simply expand provisions of present law that favor foreign investment through real estate investment trusts, such as the Real Estate Jobs and Investment Act of 2011.
Book Synopsis The US Foreign Investment in Real Property Tax Act by : Angela W. Yu
Download or read book The US Foreign Investment in Real Property Tax Act written by Angela W. Yu and published by Kluwer Law International B.V.. This book was released on 2017-10-24 with total page 384 pages. Available in PDF, EPUB and Kindle. Book excerpt: U.S. real estate is enormously attractive to many foreign investors, who are thus ushered into the ambit of the complex U.S. Foreign Investment in Real Property Tax Act (FIRPTA). A full understanding of the associated tax implications on the part of these investors and their advisors is essential if they are to implement the correct structure to maximize their returns, avoid unnecessary withholding, and comply with applicable requirements. This book, the first practical guide to FIRPTA, clearly articulates the operation and transactional implications of FIRPTA and its interaction with various other regimes, sets forth real life situations, and points out potential traps, all in a readily graspable format. Among the tax issues and consequences that directly or indirectly affect foreign investors in U.S. real property interests, the author highlights the following and more: • the real estate investment trust (REIT); • withholding taxes that are jointly and severally liable for buyers and sellers; • treatment of rental, interest, and dividend income; • effect of the branch profits tax; • tax treaty benefits; • exemptions to FIRPTA; • special rules applicable to foreign governmental investors; • tax reporting standards and potential penalties for noncompliance; and • state and local tax issues relating to U.S. real estate investments. Providing a straightforward and accessible guide for navigating the tax issues that confront foreign investors in U.S. real estate, this resource will prove invaluable in identifying and formulating the correct strategies for investors and their advisors with respect to investments in the U.S. real estate market. It is sure to benefit all interested parties for years to come. Angela W. Yu, a tax partner of KPMG’s New York office, has extensive experience providing integrated tax advice to clients on cross-border transactions. She is a frequent speaker on U.S. tax issues, and has addressed many professional organizations.
Book Synopsis Description of S. 1915 Relating to Tax Treatment of Foreign Investment in U.S. Real Property by : United States. Congress. Joint Committee on Taxation
Download or read book Description of S. 1915 Relating to Tax Treatment of Foreign Investment in U.S. Real Property written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 1984 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Foreign Investors Tax Act of 1966 by : United States. Congress. House. Committee on Ways and Means
Download or read book Foreign Investors Tax Act of 1966 written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1966 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Foreign Investment in Real Property Tax Act by : American Bar Association. Section of Taxation
Download or read book The Foreign Investment in Real Property Tax Act written by American Bar Association. Section of Taxation and published by . This book was released on 1983 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation Publisher : ISBN 13 : Total Pages :176 pages Book Rating :4.:/5 (327 download)
Book Synopsis Repeal of Foreign Investment in Real Property Tax Act by : United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation
Download or read book Repeal of Foreign Investment in Real Property Tax Act written by United States. Congress. Senate. Committee on Finance. Subcommittee on Energy and Agricultural Taxation and published by . This book was released on 1984 with total page 176 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis H. R. 11297, the Foreign Investors Tax Act of 1965 by : United States. Congress. House. Committee on Ways and Means
Download or read book H. R. 11297, the Foreign Investors Tax Act of 1965 written by United States. Congress. House. Committee on Ways and Means and published by . This book was released on 1965 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Foreign Investment in U. S. Real Estate by : Department of the Treasury
Download or read book Taxation of Foreign Investment in U. S. Real Estate written by Department of the Treasury and published by Forgotten Books. This book was released on 2015-06-14 with total page 83 pages. Available in PDF, EPUB and Kindle. Book excerpt: Excerpt from Taxation of Foreign Investment in U. S. Real Estate Dear Mr. Chairman: Section 553 of Public Law No. 95-500, the "Revenue Act of 1978," required the Treasury Department to conduct a study and analysis of the appropriate tax treatment of income from, or gain on the sale of, interest in United States property held by nonresident aliens and foreign corporations. The Secretary is required to transmit a report of the results of this study, together with the recommendations of the Department, within six months of the date of enactment of the Act. Pursuant to these provisions, I hereby submit a report entitled "Taxation of Foreign Investment in U.S. Real Estate." Under present law, capital gains realized by nonresident aliens and foreign corporations are not subject to U.S. tax unless they are "effectively connected" with a U.S. trade or business. The Treasury Report finds that, while most real property holdings of foreign person is used in a U.S. trade or business, foreign persons rarely incur capital gains tax on the disposition of their U.S. property holdings. The Report identifies various ways in which the capital gains on real estate, which would ordinarily be taxable, can be converted into capital gain on some other asset, which would not. The principal means by which this is accomplished is through a real property holding company and converting gain realized on disposition of the "effectively connected" property into gain realized on disposition of the shares, which is not deemed "effectively connected." The Treasury does not believe that taxing capital gain on the sale of corporate shares is desirable or practical. But to prevent unintended tax avoidance, the Treasury recommends modifying certain specific statutory provisions under which foreign taxpayers convert taxable gain on real estate into nontaxable gain. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.
Book Synopsis Structuring Foreign Investments in U.S. Real Estate by :
Download or read book Structuring Foreign Investments in U.S. Real Estate written by and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The 30 Percent Withholding Tax and the Foreign Investment in Real Property Tax Act by : David L. Brumbaugh
Download or read book The 30 Percent Withholding Tax and the Foreign Investment in Real Property Tax Act written by David L. Brumbaugh and published by . This book was released on 1984 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Elective Taxation on Inbound Real Estate Investment by : David Herzig
Download or read book Elective Taxation on Inbound Real Estate Investment written by David Herzig and published by . This book was released on 2016 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since 1980, the United States has taxed U.S. real property gains of foreign investors. A nonresident must pay tax on the capital gain from the sale of U.S. real property or rights in U.S. real property, as well as on the sale of shares in non-publicly held domestic corporations that hold significant U.S. real property assets. The United States imposes a withholding liability on the purchaser based on a percentage of the purchase price. Moreover, by owning U.S. real property, foreign investors are subject to Internal Revenue Service (IRS) investigatory powers. Because of these rules, foreign investors spend significant resources to structure investment in U.S. real property assets to avoid being deemed an owner of the underlying real property for taxation purposes. This has rendered the underlying statute, the Foreign Investment in Real Property Act of 1980 (FIRPTA), elective.This electivity results in the United States exhibiting tax haven characteristics for inbound real estate investments. Rather than tightening the rules to eliminate this friction, Congress has recently proposed even looser requirements. The resulting narrative by practitioners and policy makers is that FIRPTA should be eliminated. The United States currently needs more, not less, collection of taxation. The fact that FIRPTA is either easily arbitraged or not properly collected should not result in the repeal.This Article proposes a new way of addressing FIRPTA by expanding the use of reporting requirements to capture the leakage and provide a mechanism for effectively eliminating the use of structuring to avoid the tax. Through the introduction of systems recently employed in the Foreign Account Tax Compliance Act (FATCA) regime, Congress can implement an effective penalty structure to ensure proper collection of taxation and achieve the stated goal of FIRPTA -- an equal tax burden independent of the status of the investor. The goal of the proposal is to have a more cohesive and coherent FIRPTA regime by replacing a gross income tax regime with a net income tax regime with a backup withholding. Given the United States' position as a market leader in a limited market, there should be a more aggressive tax collection stance taken. The U.S. real property market is relatively inelastic as compared to equities; thus, an aggressive U.S. position will not have much if any downside.
Book Synopsis U.S.A. FOREIGN INVESTMENT IN REAL PROPERTY TAX ACT OF 1980 by : MICHAEL SCHEMMANN
Download or read book U.S.A. FOREIGN INVESTMENT IN REAL PROPERTY TAX ACT OF 1980 written by MICHAEL SCHEMMANN and published by . This book was released on 1981 with total page 93 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Structuring Foreign Investment in U.S. Real Estate by : W. Donald Knight
Download or read book Structuring Foreign Investment in U.S. Real Estate written by W. Donald Knight and published by . This book was released on 1982 with total page 684 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) by : Michael S. Leone
Download or read book Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) written by Michael S. Leone and published by . This book was released on 1985 with total page 156 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Impact of the "Foreign Investment in Real Property Tax Act of 1980" on International Tax Treaties by : Karin Elisabeth Landmann
Download or read book The Impact of the "Foreign Investment in Real Property Tax Act of 1980" on International Tax Treaties written by Karin Elisabeth Landmann and published by . This book was released on 1983 with total page 182 pages. Available in PDF, EPUB and Kindle. Book excerpt:
