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U.S. IRS Releases Updated Practice Unit on Taxation on the Disposition of USRPI by Foreign Persons

01 June 2020

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Approved Changes

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United States

The U.S. IRS has released an updated international practice unit on Taxation on the Disposition of U.S. Real Property Interest (USRPI) by Foreign Persons. The practice unit is updated to clarify that publicly traded stock of a corporation continues to not be a U.S. Real Property Interest (USRPI) if held by a 5% or less shareholder. Only for Real Estate Investment Trusts (REITs), was the 5% threshold increased to 10% or less under the Protecting Americans from Tax Hikes Act of 2015 (the "PATH Act") passed on 18 December 2015. Click the following link for the International Practice Units page...