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Introduction to the taxation of foreign investment in US ...

July 2015 Introduction to the taxation of foreign investment in US real estateContents2 Introduction 3 taxation of US entities and individuals 6 US tax implications of specific investment vehicles 9 Treaty protection from taxation 11 Dispositions of US real estate investments 14 Sovereign Wealth Funds 16 foreign Account Tax Compliance Act 18 Appendix A: foreign corporate blocker structure 19 Appendix B: Leveraged corporate blocker structure 20 Appendix C: REIT structure 21 ContactsIntroduction to the taxation of foreign investment in U S real estate 1 IntroductionWays and Means Committee Chairman Paul Ryan has also publicly indicated that the House taxwriters will have an aggressive timeline for tax reform proposals this year.

Introduction to the taxation of foreign investment in U S real estate 3. whether the activities of the US business are a material factor in generating the income. The asset-use test looks ... The portfolio interest exemption applies to qualified interest payments made to …

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