FIRPTA was enacted due to Congress’s concern that foreign persons were investing in U.S. property and selling it but not paying tax on gains.
FIRPTA was passed in order to treat gains on dispositions of U.S. real property interests as effectively connected income to a U.S. trade or business. It was enacted to ensure at least one level of U.S. tax imposed on sale of USRPI by foreign persons as foreign persons are generally not taxed on U.S. source capital gains other than U.S. real property. This video reviews U.S. real property interests and holding companies and discusses withholding taxes and certificates.
Mike Burgess, J.D.
- Serves as a senior manager with Crowe LLP’s international tax group
- Has more than 20 years of experience in international tax including both compliance and planning for public and private companies
- Has a broad range of industry experience, including manufacturing and distribution, retail and technology, among others
- Throughout his career he has acquired extensive experience in international compliance issues including completion and review of all U.S. international tax forms
- Since 2010 he has focused on providing international tax services to publicly and privately held multinational companies in the middle market on a wide range of international tax issues, including, in addition to the above, structure planning, mergers and acquisition, cross-border transactions and Subpart F analysis, GILTI, FDII, BEAT, and foreign tax credits
- Prior to joining Crowe, he spent more than 10 years in Big 4 public accounting firms where he gained an extensive background in implementing global holding company structures designed to improve a company’s tax positions and efficiently manage cash through intercompany financing and cash planning
- Has specific experience in development and implementation of international structuring and restructuring projects
- J.D. degree, Lewis & Clark College
Danish N. Meherally, J.D., LL.M.
- Manager in the Atlanta office of Crowe LLP
- Practice emphasizes all aspects of international tax
- LL.M. degree in tax , University of Florida School of Law; J.D. degree, Ave Maria School of Law
- Can be contacted at [email protected]
All of your training, right here at Lorman.
Pay once and get a full year of unlimited training in any format, any time!
- Live Webinars
- OnDemand Webinars
- MP3 Downloads
- Course Manuals
- Audio Recordings*
- Executive Reports
- White Papers and Articles
- Sponsored Live Webinars
Additional benefits include:
- State Specific Credit Tracker
- Members Only Newsletter
- All-Access Pass Course Concierge
* For audio recordings you only pay shipping
Questions? Call 877-296-2169 to speak with a real person.