For dispositions after December 17, 2015, such corporation and any predecessor of such corporation was not a RIC or a REIT during the shorter of the applicable periods during which the interest was held.
LOOKTHROUGH RATE FULL
real property interests held by such corporation at any time during the shorter of the applicable periods were disposed of in transactions in which the full amount of any gain was recognized, and real property interests on the date of disposition,
real property holding corporation during the shorter of the period during which the interest was held, or the 5-year period ending on the date of disposition (applicable periods).Īn interest in a corporation is not a U.S. It also means any interest, other than as a creditor, in any domestic corporation unless it is established that the corporation was at no time a U.S. Virgin Islands, as well as certain personal property that is associated with the use of real property (such as farming machinery). real property interest is an interest, other than as a creditor, in real property (including an interest in a mine, well, or other natural deposit) located in the United States or the U.S. real property interest, the business entity itself is the withholding agent. business entity such as a corporation or partnership disposes of a U.S. If the transferor is a foreign person and you fail to withhold, you may be held liable for the tax. If you are the transferee/buyer, you must find out if the transferor is a foreign person. In most cases, the transferee/buyer is the withholding agent. real property interests (transferees) from foreign persons, certain purchasers' agents, and settlement officers are required to withhold 15% (10% for dispositions before February 17, 2016) of the amount realized on the disposition (special rules for foreign corporations). This includes but is not limited to a sale or exchange, liquidation, redemption, gift, transfers, etc. real property interests.Ī disposition means “disposition” for any purpose of the Internal Revenue Code. FIRPTA authorized the United States to tax foreign persons on dispositions of U.S. real property interest by a foreign person (the transferor) is subject to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) income tax withholding. Withholding of Tax on Dispositions of United States Real Property Interests
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