Also found in: Financial.
FIRPTAForeign Investment in Real Property Tax Act
FIRPTAForeign Investment in Real Property Tax Act of 1980
References in periodicals archive ?
The modifications, including the new FIRPTA exemption for qualified foreign pension funds, are highly significant to certain classes of non-U.
Also, as per the acquisition, Starwood and ILG believe that any realised gain on the exchange of Vistana common stock for ILG common stock by a non-US holder, who is treated for tax purposes as having owned 5% or less of the stock of each of Starwood and Vistana between and including 28 March 2016 (the record date for the spin-off) and 11 May 2016, should not be subject to tax under FIRPTA.
If the FIRPTA changes have the intended impact, the legislation will bolster foreign capital flows that are already robust.
Foreign companies holding FIRPTA assets are subject to both corporate-level tax and withholding tax on the return they realize from U.
The proposed FIRPTA changes could spur foreign investment beyond these traditional gateway markets to other core CBD markets like Chicago and Atlanta, where investment returns have historically been somewhat lower, said Mr.
Applied retroactively, TIPRA modifies FIRPTA to target investors with significant property interests and change application for those who own 5 percent or less of certain qualified investment entities.
He regularly provides advice regarding structures for conducting global business and investment activities, establishing foreign holding companies, representative offices, branches and subsidiaries, forming offshore funds, international transfers of assets including intellectual property, and specifically on issues such as Subpart F and passive foreign investment companies, tax treaties, FIRPTA, foreign tax credits, buy-ins and cost-sharing arrangements and transfer pricing.
FIRPTA imposes a federal withholding tax on gains realized by foreign persons from the sale of US real property.
FIRPTA, as codified principally in Internal Revenue Code (IRC) [section] [section] 897 and 1445, governs the taxation of dispositions of U.
Riley, Shareholder, Greenberg Traurig, LLP will speak at the Knowledge Group's webcast entitled: "Significant Changes to the REITs and FIRPTA Rules in 2016 and Beyond Live Webcast.
Wyden added that exempting foreign pension funds from FIRPTA "would encourage private investment in infrastructure.