The government declined to adopt near-unanimous commentary on the proposed regulations recommending that the domestic C corporation “look-through” rule be withdrawn. For purposes of determining ...
On August 19, the IRS announced guidance providing relief for certain non-U.S. corporations redomiciling into the United States. Notice 2025-45 (the “Notice”) introduces an exception to the general ...
A non-US investor considering acquiring exposure to US real estate through a financial instrument should be aware of the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). FIRPTA subjects a ...
The IRS issued final regulations in response to amendments to the Foreign Investment in Real Property Tax Act (FIRPTA) made in December by the Protecting Americans From Tax Hikes Act of 2015 (PATH) ...
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