Greit liquidating trust
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.
Section 897(i): Exclusive Method of Claiming Non-Discrimination m.
Withholding by Nongrantor Trusts and Estates - "USRPI Account" c.
Sales of Interests in Partnerships, Trusts and Estates 4.
USRPHC: Establishing That a Corporation Is Not a USRPHC - Importance (1) Approach of the Regulations (2) Notice Requirements Applicable to Corporations i.
USRPHC: Indirect Asset Ownership (1) Foreign RPHC (2) USRPHC: Controlling Interests (3) USRPHC: Non-Controlling Interests (4) USRPHC: Partnership, Trust, and Estate Interests h. Distributions of USRPIs by Domestic Corporations 1. Interests Subject to Taxation Upon Later Dispositions 6. Nonrecognition Under FIRPTA - Tax-Free Transfers 1. General Rule (1) USRPI for USRPI Requirement (2) Interests Subject to Tax Upon Subsequent Disposition (3) Filing Requirements b.
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. Eligibility to Make the Election; Income to Which the Election Applies c. During his work on this Portfolio, he was an attorney in the tax group at King & Spalding LLP.
from the Fletcher School of Law and Diplomacy, and a B. He is admitted to practice in Georgia and the District of Columbia. To view this Portfolio, take a free trial to Bloomberg BNA Tax & Accounting BLOOMBERG BNA TAX & ACCOUNTING This Portfolio is available with a subscription to Bloomberg BNA Tax & Accounting, a comprehensive research solution including over 500 Tax Management Portfolios, practice tools, primary sources and timely news. He is admitted to practice in New York and the District of Columbia.