The Resource Fixing FIRPTA? (Design flaws worsen with age)

Fixing FIRPTA? (Design flaws worsen with age)

Label
Fixing FIRPTA? (Design flaws worsen with age)
Title
Fixing FIRPTA? (Design flaws worsen with age)
Creator
Subject
Language
eng
Summary
This article considers whether - from a "micro" level - foreign investors, who commonly hold U.S. real estate through one or more corporations, ordinarily bear U.S. income tax upon their disposition of interests in a corporation or partnership that holds U.S. real estate among its assets. Then it considers how changes to the Foreign Investment in Real Property Act (FIRPTA) might reach such structures "better", either by ensuring one level of tax on direct investments, or by taxing such indirect investments more consistently, regardless of whether the investment is held through a domestic or foreign blocker or domestic or foreign partnership. Some of the proposed changes represent minor "tweaks", to the FIRPTA rules, some would require new legislation, and others would reflect major departures from the present legislation
Citation source
In: Tax management international journal. - Arlington. - Vol. 42 (2013),
http://library.link/vocab/creatorName
  • Glicklich, P.A
  • Grandinetti, M.J
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • FIRPTA
  • immovable property
  • REIT
  • tax treaty
Label
Fixing FIRPTA? (Design flaws worsen with age)
Instantiates
Publication
Label
Fixing FIRPTA? (Design flaws worsen with age)
Publication

Library Locations

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