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U.S. Real Property Holding Corporation Determinations

Foreign Investment in Real Property Tax Act (“FIRPTA”) may apply to exchanges of interests in certain corporations. Certain corporations with direct and indirect interests in U.S. real estate may be treated as a U.S. Real Property Holding Corporation ("USRPHC").

Issues to Consider

Is a valuation required to make

a USRPHC determination?

Is there an alternative method

of making a USRPHC

determination?

Could equipment be treated as

a U.S. Real Property

Interest ("USRPI")?

Will I be subject to U.S. income

taxation on the sale or

exchange of my interest in

the corporation?

Do you need help with a U.S. Real Property Holding Corporation determination?
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