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Full-Text Articles in International Law
Special U.S. Rules Directly Affecting Foreign Investment, C. Tanner Rose Jr.
Special U.S. Rules Directly Affecting Foreign Investment, C. Tanner Rose Jr.
Penn State International Law Review
The purpose of this article is to provide a list of special U.S. rules which guide domestic attorneys in counseling foreign investors on tax and finance consequences of their transactions in the United States. A firm grasp of these rules, as a starting point, enables an attorney to formulate proper suggestions to foreign clients in acquiring property and conducting business without being subject to excessive tax consequences.
The Foreign Investment In Real Property Act Of 1980, Lisa B. Petkun
The Foreign Investment In Real Property Act Of 1980, Lisa B. Petkun
Penn State International Law Review
For a number of years, foreign investors were able to invest in real property located in the United States and to avoid, to a great extent, the payment of United States income tax on the operating income from the property and on the gain realized upon the disposition of the property. However, with the enactment of the Foreign Investment in Real Property Tax Act of 1980 ("FIRPTA") the ability of foreigners to avoid the United States tax gains realized upon the sale of real property located in the United States has been greatly circumscribed. To accomplish this result, FIRPTA added …
United States Taxation Of Foreign Direct Investment, Alan G. Cohate
United States Taxation Of Foreign Direct Investment, Alan G. Cohate
Penn State International Law Review
This article, while broad in scope, is narrow in focus. It aims solely at those aspects of the United States' internal tax laws which should be considered by the foreign investor in planning for his investment. These tax considerations may affect the structure of operation of the business enterprise in the United States. The article is not intended as a short course in United States taxation, and the reader should be aware that the complexities of the United States Internal Revenue Code and the regulations issued thereunder are so great that no particular fact situation can be correctly analyzed except …