The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of a U.S. real property interest (USRPI) by treating such gain as effectively connected with the conduct of a U.S. trade or business by such non-U.S. persons (effectively connected income, or ECI).

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Tags: Foreign Investment in Real Property Tax Act, GT Insight, IRS, Tax, Treasury Department
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Photo of Pallav Raghuvanshi Pallav Raghuvanshi

Pallav Raghuvanshi focuses his practice on U.S. and international tax matters in the context of corporate restructurings and cross-border mergers and acquisitions. He is experienced handling spin-off transactions for large multinational companies, various inbound and outbound transactions involving issues related to foreign tax…

Pallav Raghuvanshi focuses his practice on U.S. and international tax matters in the context of corporate restructurings and cross-border mergers and acquisitions. He is experienced handling spin-off transactions for large multinational companies, various inbound and outbound transactions involving issues related to foreign tax credits, tax treaties, controlled foreign corporations, and other international reorganization issues. He also handles U.S. federal tax aspects of initial coin offering / first token sales and other tax-related issues on blockchain technology and cryptocurrencies.

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Photo of Robert D. Simon Robert D. Simon

Robert D. Simon assists clients in the tax ramifications of cross-border transactions. He frequently advises clients involved in mergers, acquisitions, restructurings, and dispositions of public and private companies. Bob has been involved in planning a number of major domestic and international reorganizations and

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Robert D. Simon assists clients in the tax ramifications of cross-border transactions. He frequently advises clients involved in mergers, acquisitions, restructurings, and dispositions of public and private companies. Bob has been involved in planning a number of major domestic and international reorganizations and spin-offs.

Bob has broad experience in tax planning for U.S. corporations operating abroad, including internal structuring for optimal tax results. His international tax practice is focused on all areas of “outbound” investment – emphasizing foreign tax credit planning, tax deferral, holding companies, the tax-efficient use of debt, the repatriation of foreign earnings, tax treaties and management of a company’s worldwide effective tax rate.

Bob also advises foreign corporations who are purchasing U.S. businesses or expanding their existing U.S. operations. He has advised on all aspects of “inbound” investment, including capitalization of U.S. operations, restructuring, withholding tax, the repatriation of earnings, tax treaties and foreign investment in U.S. real property. Bob assists many foreign natural resource companies on their U.S. operations and acquisitions. Bob also advises real estate funds and investors, particularly with respect to the U.S. income tax consequences of investments by foreign investors, including sovereign wealth funds and pension funds.

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