Dispositions of US Real Property Interests by Foreign Persons

The Foreign Investment in Real Property Tax Act 1980 (commonly known as ‘FIRPTA’) introduced tax and reporting requirements designed to ensure the imposition and collection of tax on gain recognized upon a foreign owner’s disposition of US real property. These rules, further complicated by detailed regulations, can apply regardless of whether the foreign person owns US real property interests outright, through a corporate structure or in trust. The Internal Revenue Service (IRS) recently announced that it will issue regulations revising rules for inbound and foreign-to-foreign asset reorganizations that involve the transfer of US real property interests. September 14, 2006. Download