Add to ORKGThe purpose of this Recent Development is to explain the effects of section 897 in terms of the problems it was designed to remedy. Part I will explore the methods that were used in the past by non-resident aliens and foreign corporations to avoid the payment of capital gains tax on the disposition of real property held in the United States. Part II will examine the newly implemented section 897 to determine how it will be applied and whether it is likely to achieve the goal of equal tax treatment for domestic and foreign investors on the disposition of United States real property
Decedent, a citizen and resident of France, was the sole income beneficiary of a trust fund held in ...
The tax advantages once granted a foreigner using a foreign corporation to invest in United States r...
One possible method of reducing United States income tax liability is to expatriate, or renounce Uni...
The purpose of this Recent Development is to explain the effects of section 897 in terms of the prob...
For a number of years, foreign investors were able to invest in real property located in the United ...
This Article first discusses the United States tax treatment of foreigners generally and the pre-For...
The impact of the United States\u27 Tax Reform Act of 1986 has been significant. The Act has created...
Since 1980, the United States has taxed U.S. real property gains of foreign investors. A nonresident...
This paper describes some of the possible structuring alternatives a foreign investor may use to lim...
This article describes the basic principles of U.S. federal income tax liability under the Foreign I...
The purpose of this thesis is to examine the impact of the new Canadian Income Tax Act on real estat...
Taxpayer, trustee of a domestic inter vivos trust, sued for a refund of United States income taxes p...
This article discusses basics that need to be considered when advising foreign clients who are plann...
The author reviews the current increased activity in and attractiveness of investment in United Stat...
This Note will examine the United States tax treatment of foreign source income, under sections 911 ...
Decedent, a citizen and resident of France, was the sole income beneficiary of a trust fund held in ...
The tax advantages once granted a foreigner using a foreign corporation to invest in United States r...
One possible method of reducing United States income tax liability is to expatriate, or renounce Uni...
The purpose of this Recent Development is to explain the effects of section 897 in terms of the prob...
For a number of years, foreign investors were able to invest in real property located in the United ...
This Article first discusses the United States tax treatment of foreigners generally and the pre-For...
The impact of the United States\u27 Tax Reform Act of 1986 has been significant. The Act has created...
Since 1980, the United States has taxed U.S. real property gains of foreign investors. A nonresident...
This paper describes some of the possible structuring alternatives a foreign investor may use to lim...
This article describes the basic principles of U.S. federal income tax liability under the Foreign I...
The purpose of this thesis is to examine the impact of the new Canadian Income Tax Act on real estat...
Taxpayer, trustee of a domestic inter vivos trust, sued for a refund of United States income taxes p...
This article discusses basics that need to be considered when advising foreign clients who are plann...
The author reviews the current increased activity in and attractiveness of investment in United Stat...
This Note will examine the United States tax treatment of foreign source income, under sections 911 ...
Decedent, a citizen and resident of France, was the sole income beneficiary of a trust fund held in ...
The tax advantages once granted a foreigner using a foreign corporation to invest in United States r...
One possible method of reducing United States income tax liability is to expatriate, or renounce Uni...