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 introduces a variety of intelligence phenomena starting from the birth of the universe, including intelligence in physics, intelligence in chemistry, intelligence in biology, intelligence in humans and intelligence in machines. It uncovers the mystery of intelligence to the world and explores the natural phenomenon of intelligence. If understanding intelligence is regarded as a journey of a thousand miles, then this book is the first step to try. In the process of studying the phenomenon of intelligence and the nature of intelligence, our eyes cannot be limited to human intelligence. Instead, one should put our vision beyond human intelligence, consider different things in the universe, reach a new level, and study and explore the phenomenon of intelligence and the essence of intelligence on a new level. By looking at the various phenomena of intelligence since the birth of the universe, readers can see that intelligence is a natural phenomenon, similar to other natural phenomena (e.g., the rolling of rocks and the melting of snow and ice). These phenomena occur to facilitate the stability of the universe, and the phenomenon of intelligence is no exception. The book is divided into 10 chapters, covering matter, energy and space in the origin of the universe, gravity in physics, the principle of least action, dissipative structures in chemistry, entropy increase, maximum entropy production, the definition of life, the emergence of life, the intelligence in plants, the intelligence in animals, the neocortex structure of the brain, the special thinking of human beings, the theory of the brain, artificial intelligence symbolism, connectionism, behaviorism, artificial general intelligence, metaverse, etc. This book can be used as a reference for students and researchers working in the artificial intelligence areas. It is also positioned as a popular science book interested in intelligent phenomena.
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.
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