Liquidating trust grantor letter
The principal subject areas of this Portfolio include: (1) the U. income tax regime applicable to foreign persons during the ownership phase of U. real estate (including summaries of certain key domestic tax rules affecting real estate); (2) the taxation of U. real property interest dispositions under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA); (3) the FIRPTA withholding tax provisions; and (4) the basic estate and gift tax rules applicable to foreign persons. Caballero was also an international tax partner in the Washington, D. She chaired King & Spalding's tax group from 2002–2007. Real Estate, discusses the federal tax rules bearing upon foreign investment in U. The Detailed Analysis contains a discussion of the various federal tax rules one will encounter when addressing this topic. Suzanne Feese was a tax partner at King & Spaulding LLP from 1995–2009 and a tax associate at King Spaulding from 1988–1994.
Withholding by Nongrantor Trusts and Estates - "USRPI Account" c.
Dispositions by Foreign Partnerships, Trusts, or Estates a.
IRS Withholding Certificate Obtained (1) Disposition of Partnership Interests (2) Dispositions by Domestic Partnerships f.
Information Reporting and Record Maintenance Requirements III.
Income Taxation of Foreign Persons' Disposition of U.
Deductions (1) Depreciation (2) Interest (a) Earnings Stripping (b) Deferral of Deduction Until Paid (c) Imputed Interest (d) Mandatory Capitalization of Interest Expense (3) Ad Valorem Real Property Taxes (4) Discretionary Capitalization of Interest and Taxes b.