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The Recently Enacted “PATH” Act Of 2015 Drastically Changes And Improves The US Federal Income Tax Rules For Certain Foreign Retirement And Pension Funds Investing In Real Estate In The United States
Posted on: Jan. 4, 2016, 5:46 p.m.
Under the US tax laws, foreign persons are typically not subject to US tax payment and US tax filing requirements with respect to US-source capital gains, unless such capital gains are treated as (or deemed to be) income that is effectively connected with the conduct of a trade or business in the United States (“Effectively Connected Income”). FIRPTA includes within Effectively Connected Income: (i) gains from the sale or disposition of a “United States real property interest” (“USRPI”), which includes ... Full investment news article