Fixing FIRPTA? (Design Flaws Worsen with Age).

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    • Abstract:
      The article discusses possible changes to the U.S. Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) to benefit foreign investors who commonly hold U.S. real estate through one or more corporations. The ramifications of either ensuring one level of tax on indirect investments or taxing indirect investments more consistently are addressed. The deferral of shareholder-level tax through a U.S. blocker when acquiring U.S. property is also considered.