ARTICLE HUB

FIRPTA ARTICLES

FIRPTA governs the withholding obligations that arise when a foreign person sells U.S. real property. Getting the rate, timing, or exemption analysis wrong can trigger significant IRS exposure to risks and penalties for buyers, sellers, and closing agents alike from a transaction.

 

These FIRPTA articles cover withholding certificates, short sales, FIRPTA withholding mechanics, including exceptions and options for reducing or eliminating the withholding.

ITIN

ARTICLES

An Individual Taxpayer Identification Number (ITIN) is often the first challenge a nonresident taxpayer faces when engaging with the U.S. tax system, whether for a real estate sale, rental of U.S. real estate, a tax return filing, or treaty benefit claims.

 

These articles cover ITIN application requirements, common rejection reasons, and how ITIN timing interacts with FIRPTA withholding and filing deadlines.

 

NONRESIDENT TAX ARTICLES

Nonresident alien taxation involves a distinct set of rules, from withholding requirements, source-of-income determinations, treaty tiebreaker provisions and the saving clause. These can differ sharply from the rules governing U.S. citizens and residents.

 

These articles explain tax requirements unique to owning or renting real estate in the United States, laws specific to rental of FLorida properties, options if you failed to report rental income.

ADVISORY ARTICLES

Beyond withholding and filing mechanics, foreign investors and nonresident individuals often need broader guidance on structuring U.S. transactions, transferring U.S. situs property, and planning for long-term tax efficiency whether for income or estate tax purposes.

 

These articles address options for taking titile, disregarded entity reporting, the substantial presence test, and practical compliance considerations for those with U.S. tax touchpoints.