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FIRPTA for REITs update (Foreign Investment in Real Property Tax and PATH Act) - Webinar

  • ID: 4409992
  • Webinar
  • 90 Minutes
  • Lorman Business Center, Inc.
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Learn about the latest issues and implications of FIRPTA for REITs.

You will learn about these issues from the managing director of FIRPTA refunds, a division of Forensic Professionals Group USA that specializes in services to foreigners, obtaining tax identification numbers from the IRS, filing for FIRPTA withholding reductions and refunds in commercial and residential properties nationwide to a Global clientele. He is used to explaining the complexities in a simple understandable manner. He brings more than 40 years of tax advantaged real estate disposition and mortgage financing experience to the table and is a go to source on the topic of FIRPTA.

Whether you are investing in REITs, selling properties to or buying properties from REITs, or are investing in real properties in the USA as a foreigner or selling to a foreigner, the updates on FIRPTA withholding and tax rules enacted under the PATH Act can have powerful implications to your bottom line.

Learning Objectives
  • You will be able to identify FIRPTA treatment of gains and losses for foreign persons disposing USRPI as ECI.
  • You will be able to recognize REIT FIRPTA rules and regulations and be able to discuss and identify these as they pertain to and are changed by the PATH Act.
  • You will be able to discuss the complex expanded rules REIT insiders manage in their applicable transactions.
  • You will be able to explain how FIRPTA impacts the specialties of investing in REITs the practical application of investing directly in U.S. Real Property Holding Companies owning U.S. Real Property Interests buying, selling US Real Property Interests and managing USRPI properties.
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PATH Act REIT Amendments to FIRPTA Opens the Flood Gates to Foreign Investment in U.S. Real Property
  • Implications of Qualifying Foreign Pension Funds No Longer Subject to FIRPTA
  • Re-Evaluation and Restructuring Considerations for REITs, Those Selling and Servicing Properties and Investors
  • Discuss Increased Exposure Buyers of REITs and U.S. Real Properties and Their Withholding Agents Have Under the New Changes
Effects of FIRPTA PATH Act Amendments on Taxation for Foreign Investors
  • Changes to Withholding Rate on Distributions
  • Defining U.S. Real Property Interests (USRPI)
  • Defining Effectively Connected Income to the Trade or Business of USRPI
  • Defining Fixed, Determinable, Annual or Periodical Income (FDAP)
  • As ECI and Non ECI
  • Partnership, Trusts and Estates Selling Interests
  • Special Rules for Foreclosures and Deeds-In-Lieu
  • Foreign Persons and Entities, Gifts and Refunds of Withholding
  • Tax Benefits of Treaties and Restrictions on Disregarded Entities
Updates on Tax Identification Numbers for Foreigners
  • Changes to the ITIN Rules
  • IRS Certified Acceptance Agents Authorized by the IRS Facilitate the ITIN Application Process
  • ITIN Changes and Renewal Requirements
Effects of Path Act Amendments to REIT Rules Affect Organizers and Investors
  • Tax Free REIT Spinoff Restrictions
  • Changes to Percentages of Maximum Stock Ownership Exceptions in Publically Traded REITs
  • Presumptions of Domestic or Foreign Control Enhancements for Establishing Foreign Status
  • FIRPTA Restrictions to the Cleansing Act
Topical Highlight of REIT Rule Changes From PATH Act, Aside From FIRPTA Changes
  • Issues and Changes Affecting Buyers of Properties, Sellers of Properties Investors and Organizers of REITs
  • Reduction in Recognition Period for REITs Acquiring C Corporations
  • REIT Ownership of Securities of a Taxable REIT Subsidiary (TRS)
  • REIT Prohibited Transaction Safe Harbors
  • REIT Preferential Dividend Rule
  • Dividend Designation Limits Set for REITs
  • Debt and Mortgage Interests
  • REITs Personal Property Assets
  • REITs Benefits From Expanded Rules Relating to Hedging Transactions
  • Taxable REIT Subsidiaries (TRS)
Some Examples of the Effect on Sample Transactions
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Richard Merrill Kahn - FIRPTA Refunds d/b/a of Forensic Professionals Group USA, Inc.
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This webinar is designed for attorneys, property managers, building owners and managers, real estate professionals, landlords, developers, presidents, vice presidents and accountants.
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