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Vol 22 No 4 April/May 2017

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Whistleblowing: Law and Practice

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Structuring Foreign Investment in US Real Estate Looseleaf

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ISBN13: 9789041128102
Latest Release: March 18, 2013
Publisher: Kluwer Law International
Country of Publication: Netherlands
Format: Looseleaf, 1 Volume
Price: £336.00
Subscription Type: Pay-as-you-go

This is a Print On Demand Title.
The publisher will print a copy to fulfill your order. Books can take between 1 to 3 weeks. Looseleaf titles between 1 to 2 weeks.

Foreign investors and their American counterparts generally share the goal of minimizing income tax liabilities from their US real estate investments. This rather straightforward aim is complicated by the fact that non-US investors must be concerned not only with income taxes in the United States, but in their home country as well. What's more, the United States has a special income tax regime that’s applicable to foreign persons. It’s quickly evident to those involved that this is a complex area subject to new developments as the US Congress continually entertains new tax laws (and other statutes with relevant impact like the PATRIOT Act), the Internal Revenue Service promulgates regulations, rulings, announcements and interpretations, and the US courts issue opinions impacting the area.

This timely and highly practical resource is designed to explore the considerations that are of unique concern to foreign individuals and entities making US real estate investments. To that end it details the US income, estate and gift tax aspects of inbound investment in US real property and the various structural techniques that may be employed to reduce or eliminate US tax liability under these domestic laws. This work's single-minded focus on real estate, the encyclopedic coverage of relevant tax considerations, and extensive materials on non-tax issues (asset protection, non-tax reporting, limits on foreign ownership of U.S, real estate, etc.) make it an essential resource for non-US investors and their advisers.

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Banking and Finance, Looseleaf Work
Chapter 1 The `Ground Rules' of the Internal Revenue Code: Rental Income;
Chapter 2 The `Ground Rules' of the Internal Revenue Code: Interest, Dividends and the Branch Profits Tax;
Chapter 3 The `Ground Rules' of the Internal Revenue Code: Sales and other Dispositions;
Chapter 4 Enforcement of the FIRPTA Tax: Withholding;
Chapter 5 The Effect of Tax Treaties on the Code Ground Rules;
Chapter 6 Legal Structure Alternatives;
Chapter 7 Special US Tax Planning Techniques and Considerations;
Chapter 8 US Estate, Gift, and Generation-Skipping Taxes;
Chapter 9 State and Local Considerations;
Chapter 10 Transfer of Ownership of US Real Property under a “Home Country” or US Will;
Chapter 11 Planning Techniques to Avoid US Probate of a Will;
Chapter 12 Introduction to Federal Disclosure Laws with Respect to Foreign Investment in US Real Estate;
Chapter 13 Responding to Foreign Direct Investment: Current Federal Disclosure Laws from an Historical Perspective;
Chapter 14 Disclosure of Real Estate Investments under the International Investment Survey Act of 1976 (Reentitled the International Investment and Trade in Services Survey Act) (the IISA);
Chapter 15 Disclosure, Requirements of the Agricultural Foreign Investment Disclosure Act of 1978;
Chapter 16 The FIRPTA Disclosure Requirements;
Chapter 17 State Restrictions and Reporting Requirements;
Chapter 18 Structures to Protect US Assets against the Effects of Foreign Political Emergencies;
Chapter 19 Structures to Protect US Assets against Freezing or Vesting under the US Trading with the Enemies Act and Related Laws;
Chapter 20 Structures to Protect US Assets in Insolvency Situations;
Appendix A Internal Revenue Code Sections 861-897;
Appendix B Internal Revenue Code Sections 1441-1446; 1461-1464; 6039C;
Appendix C Income Tax Regulations Issues Under Code Section 897;
Appendix D Income Tax Regulations Issues Under Code Section 1445;
Appendix E Internal Revenue Code Sections 2001; 2003-2041; 2051-2055; 2102-2108; 2501-2551; 2061-2663;
Appendix F The Agricultural Foreign Investment Disclosure Act of 1978;
Appendix G The International Investment Survey Act of 1976, re-entitled ‘The International Investment and Trade in Services Act’;
Appendix H Instructions for FIRPTA Withholding Certificate Applications;
Appendix I Internal Revenue Service Form 8288-A (Statement of Withholding on Dispositions by Foreign Persons of U.S. Real Property Interests);
Appendix J Internal Revenue Service Form 8288-B (Application for Withholding Certificate for Dispositions by Foreign Persons of U.S. Real Property Interests);
Appendix K Internal Revenue Service Revenue Procedure 2000-35

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