Long awaited legislative proposals for the Clean Technology Manufacturing (”CTM”) Investment Tax Credits (“ITC”) were issued in late 2023 (the “CTM ITC Proposals”). The CTM ITC provides for a headline 30% refundable ITC for qualifying CTM expenditures. The CTM ITC...
On May 12, 2023, IRS Office of Chief Counsel issued GLAM 2023-003 (the “GLAM”) analyzing the application of the “regularly traded stock exception” in Section 897(c)(3) to stock of a US real property holding corporation (“USRPHC”) held by partnerships. Though not...
By now, most foreign investors that are investing in US real property or US infrastructure projects have likely encountered the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”). In general, FIRPTA was enacted to impose a tax on gains derived by foreign...
What is FIRPTA? The Foreign Investment in Real Property Tax Act (FIRPTA) is a tax law that enables the IRS to tax non-US persons on their dispositions of U.S. Real Property Interests (USRPI). Understanding the application of FIRPTA is critical in conducting tax...
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