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Excerpt from Taxation of Foreign Investment in U. S. Real Estate Selected Balance Sheet and Income Statement Items by Type of Return and Selected Industry (money Amounts are in Millions of Dollars) About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.
Excerpt from Prentice-Hall Tax Service for 1919 This allowance is not based upon the difference between the actual war cost of such facilities and what they would have cost at pre-war prices. Obviously the taxpayer is not entitled to recover or extinguish through amortization more than the difference between the war cost of such property and what he can sell the property for after the war, or if he continues to need and use it in his business, what it would have cost him after the war. As the rule is expressed in Article 183 of the Regulations: The total amount to be extinguished by amortization, in general, is the excess of the unextinguished or unrecovered cost of the property over its maximum value (either for sale or for use as part of the plant or equipment of a going business) under stable post war. Conditions.' About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully; any imperfections that remain are intentionally left to preserve the state of such historical works.
U.S. real estate is enormously attractive to many foreign investors, who are thus ushered into the ambit of the complex U.S. Foreign Investment in Real Property Tax Act (FIRPTA). A full understanding of the associated tax implications on the part of these investors and their advisors is essential if they are to implement the correct structure to maximize their returns, avoid unnecessary withholding, and comply with applicable requirements. This book, the first practical guide to FIRPTA, clearly articulates the operation and transactional implications of FIRPTA and its interaction with various other regimes, sets forth real life situations, and points out potential traps, all in a readily graspable format. Among the tax issues and consequences that directly or indirectly affect foreign investors in U.S. real property interests, the author highlights the following and more: • the real estate investment trust (REIT); • withholding taxes that are jointly and severally liable for buyers and sellers; • treatment of rental, interest, and dividend income; • effect of the branch profits tax; • tax treaty benefits; • exemptions to FIRPTA; • special rules applicable to foreign governmental investors; • tax reporting standards and potential penalties for noncompliance; and • state and local tax issues relating to U.S. real estate investments. Providing a straightforward and accessible guide for navigating the tax issues that confront foreign investors in U.S. real estate, this resource will prove invaluable in identifying and formulating the correct strategies for investors and their advisors with respect to investments in the U.S. real estate market. It is sure to benefit all interested parties for years to come. Angela W. Yu, a tax partner of KPMG’s New York office, has extensive experience providing integrated tax advice to clients on cross-border transactions. She is a frequent speaker on U.S. tax issues, and has addressed many professional organizations.
This book offers a broad introduction to the changing status & legal requirements for foreign direct investment in the United States. It is written for both the foreign businessperson interested in entering the U.S. market & lawyers advising potential foreign investors. (Extensive footnotes are included for the latter.) To inform readers of the most important changes in the law, this third edition contains new chapters on such topics as state laws & regulations, & distribution & sales methods for entering the U.S. market. Updated chapters from the second edition cover accounting requirements; taxation; real estate; regulation of foreign investment; immigration; patents, trademarks, & copyrights; torts & products liability; & competing for government contracts.
This book covers expert papers presented in honour of John G. Head. These contributions review the principal themes dominating tax debate and tax reform at the end of the century. The book is divided into six parts: "Tax reform overview"; "The political economy of taxation"; "Consumption tax or income tax"; "Issues in the taxation of income"; "International aspects of taxation"; "Interaction of tax and expenditure". (Contributors amongst others: R. Musgrave, T. Edgar, S. Cnossen, A. Easson, P.B. Musgrave, R.M. Bird).