New IRS guidance issued on qualified foreign pension fund exception. On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for ...
On May 19, 2023 the Internal Revenue Service (IRS) released AM 2023-003 (the Memo or GLAM) holding that the Foreign Investment in Real Property Tax Act's (FIRPTA's) 5% publicly traded exception (the 5 ...
The Foreign Investment in Real Property Tax Act (FIRPTA) requires most foreigners who sell or otherwise dispose of U.S. real property to pay capital gains tax on any profits. To make sure the tax is ...
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