目次

1 The Genesis of FIRPTA and Related Background 2 Structuring Foreign Investments in the United States 3 Definition of a US Real Property Interest 4 Definition of a US Real Property Holding Company 5 Using REITs to Invest in the US 6 Exceptions to FIRPTA 7 FIRPTA Nonrecognition Rules 8 FIRPTA Withholding 9 Impact of US Income Tax Treaties 10 Entity Classifications and Interest Deductions 11 Tax Administration, Penalties, and Interest 12 State and Local Tax Considerations 13 Income and Transfer Tax Issues Applicable to Foreign Individual Investors