Tag Archives: IRS

Proposed Regulations for Qualified Foreign Pension Funds that are Exempt from U.S. Tax on Disposition of U.S. Real Property Interests

The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of a U.S. real property interests (USRPI) by treating such gain as effectively connected with the conduct of a U.S. trade or business by such non-U.S. … Continue Reading

Welcome News for Non-U.S. Persons Investing into U.S. Businesses: U.S. Tax Court Rejects Long-Standing IRS Ruling

On July 13, 2017, the U.S. Tax Court, in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner,1 rejected the long-standing Internal Revenue Service (IRS) position that a non-U.S. person is taxed on the sale of an interest in an entity that is a “partnership” for U.S. federal income tax purposes (hereinafter, a partnership) … Continue Reading
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