tailieunhanh - Introduction to the taxation of foreign investment in U.S. real estate

Tham khảo sách 'introduction to the taxation of foreign investment in . real estate', tài chính - ngân hàng, đầu tư bất động sản phục vụ nhu cầu học tập, nghiên cứu và làm việc hiệu quả | Deloitte Introduction to the taxation of foreign investment in . real estate February 2010 Contents Introduction 1 Taxation of income from . real estate 2 Taxation of . entities and individuals 2 Taxation of foreign entities and international investors 2 . trade or business 2 Effectively connected income 3 Noneffectively connected income 3 Net basis elections 4 Branch Profits Tax 4 Tax on excess interest 4 . withholding tax on payments made to the foreign investor 5 . tax implications of specific investment vehicles 6 . corporations 6 Foreign corporations 7 Partnerships 7 Real Estate Investment Trusts 8 T reaty protection from taxation 10 Dividend income 10 Branch Profits Tax 10 Interest income 11 Business profits 11 Income from real property 11 Capital gains 11 Third country use of treaties limitation on benefits 11 Dispositions of . real estate investments 12 . real property interests 12 Definition of a USRPHC 12 Why is USRPHC status important 13 . tax consequences of investing in USRPIs through foreign corporations 13 Election to be treated as a domestic corporation 14 Use of REITs 14 FIRPTA withholding 14 Withholding exceptions 14 Sovereign Wealth Funds 16 Section 892 exemption 16 Foreign government 16 Exempted income 17 Commercial activities exclusion 17 REIT issues and Notice 2007-55 18 Appendix A Foreign corporate blocker structure 19 Appendix B Leveraged corporate blocker structure 20 Appendix C REIT structure 21 Contacts 22 Introduction Impact of taxes on real estate Real estate is very much a tax-driven industry. As a result changes in . tax policy have an impact on the relative attractiveness of real estate as an investment class for . investors. Increases to the . tax rates on capital gains the taxation of the dispostion of real estate and . tax reporting requirements are often cited as examples of policies that create obstacles to investment. Over the years real estate organizations in the . have offered