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
Taxpayer, trustee of a domestic inter vivos trust, sued for a refund of United States income taxes p...
Compliance reporting procedures for foreign investors in U.S. real estate were instituted by the Fo...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...
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...
This article describes the basic principles of U.S. federal income tax liability under the Foreign I...
This article discusses basics that need to be considered when advising foreign clients who are plann...
This paper describes some of the possible structuring alternatives a foreign investor may use to lim...
The author reviews the current increased activity in and attractiveness of investment in United Stat...
The purpose of this thesis is to examine the impact of the new Canadian Income Tax Act on real estat...
The recent interest in U.S. farmland purchases by non-resident foreign investors evidences the attra...
Prior to 1937, it was common for United states taxpayers to utilize offshore corporate entities, str...
Because of the current low capital gains rates, many speculative investors are selling large parcels...
Taxpayer, trustee of a domestic inter vivos trust, sued for a refund of United States income taxes p...
Compliance reporting procedures for foreign investors in U.S. real estate were instituted by the Fo...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...
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...
This article describes the basic principles of U.S. federal income tax liability under the Foreign I...
This article discusses basics that need to be considered when advising foreign clients who are plann...
This paper describes some of the possible structuring alternatives a foreign investor may use to lim...
The author reviews the current increased activity in and attractiveness of investment in United Stat...
The purpose of this thesis is to examine the impact of the new Canadian Income Tax Act on real estat...
The recent interest in U.S. farmland purchases by non-resident foreign investors evidences the attra...
Prior to 1937, it was common for United states taxpayers to utilize offshore corporate entities, str...
Because of the current low capital gains rates, many speculative investors are selling large parcels...
Taxpayer, trustee of a domestic inter vivos trust, sued for a refund of United States income taxes p...
Compliance reporting procedures for foreign investors in U.S. real estate were instituted by the Fo...
The sale of property by a taxpayer to a corporation which he controls has been a frequently attempte...