Foreign Investment in U.S. Real Estate: Reporting and Avoiding Withholding, Holding Structures, ECI and FDAP
Recording of a 110-minute CPE webinar with Q&A
This course will explain the complexities of taxation and withholding on foreign investment in U.S. real property. Our panel of multinational tax veterans will focus on strategies to minimize taxation of these properties--whether held individually or through an entity--for tax practitioners working with nonresident aliens (NRAs).
Outline
- FIRPTA, an introduction
- Effectively connected income
- Fixed and deteriminable periodic or annual income
- Withholding
- Current income
- Sales proceeds
- Ownership structures
Benefits
The panel will review these and other key issues:
- Which taxpayers are subject to mandatory withholding on sales of U.S. real estate?
- What criteria must be met for income from U.S. real estate to be categorized as ECI?
- Who is obligated to withhold and remit withholding taxes under Section 1445(a) on property transfers?
- Under what circumstances should an NRA consider holding a U.S. real estate interest in an LLC?
Faculty
Patrick J. McCormick, J.D., LL.M.
Partner
Culhane Meadows Haughian & Walsh
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.
CloseMark Perlberg, CPA, CTC
Founder
Mark Perlberg, CPA
Mr. Perlberg has a passion for entrepreneurship and helping people navigate the complex world of accounting and taxes... | Read More
Mr. Perlberg has a passion for entrepreneurship and helping people navigate the complex world of accounting and taxes to reach their goals. He worked as a real estate agent in New York City before studying accounting in order to provide clients a greater understanding of financial decisions that impact them and their businesses.
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CPE credit is not available on downloads.
CPE On-Demand