U.S. Tax Issues for Foreign Persons Investing in the U.S. Real Property: FIRPTA, PATH Act and More - New York

New York, NY

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Join us for a NEW two-day seminar on the rules that apply to foreign investors in U.S. real property as well as the latest developments affecting the area. Leading practitioners in the area will review the basics and build through a variety of common investment situations including investment in oil and gas property, investments by specialized types of investors such as foreign governments and foreign not-for-profit organizations, investments in special vehicles such as Real Estate Investment Trusts. Foreign persons investing in the United States potentially must focus on the tax rules in three jurisdictions: their home country, a country through which they might invest, and the United States.


All paid attendees will receive the Bloomberg BNA Portfolio:
U.S. Taxation of Foreign Investment in U.S. Real Estate (Portfolio 912-2nd)
*One Portfolio per paid attendee. Quantities are limited.

Benefits of Attending:
• Learn about the federal, state and local tax rules as well as the impact of U.S. income tax treaties, tax planning in the investor’s home country, and disclosure and reporting obligations including the new FinCEN rules and local reporting requirements
• Examine the rules governing investments in U.S. oil and gas properties and REITs, as well as investments by foreign governments and foreign exempt organizations
• Review a number of real-life case studies in a workshop session that will bring together the rules in a cohesive and user-friendly manner

Why You Should Attend
The United States taxing rules are complex. In addition, there are broad withholding tax rules that create many potential problems and pitfalls. Common issues, best practices and other approaches to dealing with issues will be discussed. This seminar will have multiple case studies as well as a detailed question and answer detail period for questions proposed by attendees.

Who Should Attend
This seminar will provide live group instruction by leading tax practitioners in the field. It is intended for tax practitioners, real estate professionals, and advisors who assist foreign persons investing in the United States real property to understand the rules that they face and planning that can facilitate such an investment and properly address their clients’ needs. This program is both transitional and transactional. It is appropriate for young practitioners, experienced practitioners but not in the area and those who have material experience in advising clients on investing in U.S. real property. There are no prerequisites for this program.



8:00 AM    Registration & Continental Breakfast

8:30 AM    Welcome and Overview

9:00 AM    The Operating Rules - FIRPTA
• Fundamental and basic rules
• What is a U.S. Real Property interest?
• Rules specific to various types of entities
• Investments by foreign governments/foreign governmental entity
• PATH Act Changes

10:30 AM   Coffee Break

10:45 AM   Withholding
• FIRPTA Withholding Rules
• §1446 Withholding
• Avoiding or reducing withholding
• Who must withhold

12:15 PM   Luncheon

1:00 PM   State and Local Taxation
• Income and franchise tax
• Other State and Local Taxes
• State withholding taxes

2:00 PM   Special Rules for Transfers
• Possible tax-free transactions including exchanges, and refinancings
• Restructurings including tax-free reorganizations, 351 transactions, liquidation and others
• Impact of U.S. Tax Treaties

3:00 PM  Coffee Break

3:15 PM  Basic Case Studies

4:45 PM  Meeting Adjourns for the Day


8:00 AM   Continental Breakfast

8:30 AM   REITs, Foreign Governments, Other Special Situations
• Public vs. Private REITs
• Domestically Controlled REITs
• Withholding Taxes

9:30 AM Foreign Pension Plans
• Qualified Foreign Pension Funds: Who Qualifies and Who is Affected?
• Withholding Taxes

10:30 AM   Coffee Break

10:45 AM   Reporting Issues
• FIRPTA reporting
• FinCEN (Manhattan and Miami), FBAR
• Reporting Ownership (New York City)
• Common Reporting Standards (CRS)

12:00 PM   Luncheon

1:00 PM   Tax treaties; Home Country Taxation
• Tax Treaties including Canada, Germany, Japan
• Home County Taxation
• Foreign Tax Credits

2:00 PM   Advance Case Studies

2:45 PM   Coffee Break

3:00 PM   Advance Case Studies (continued)

4:00 PM   Questions & Answers

4:30 PM   Conference Concludes


November 30 - December 1, 2016


AMA Conference Center  
1601 Broadway (at 48th and Broadway)
8th Floor
New York, NY 10019

Hotel accommodations are at your own discretion. We suggest the following:

Belvedere Hotel
319 West 48th Street
New York, NY 10036
Tel: (212) 245-7000

Novotel of New York
226 West 52nd Street
New York, NY 10019
Tel: (212)-315-0100



If you are unable to attend this event, you may: transfer your registration to another person from your company for the same event; or transfer your registration to a substitute event listed on our web site. In either instance, there will be no charge or penalty for substitution. To request a transfer, contact with the new attendee or substitute event information more than 5 business days prior to the conference start date. On the first day of the event, absent attendees will be considered “no shows” and will not be eligible for a refund, transfer, or substitute event.

Cancellations must be made in writing to more than 5 business days before the event and will be assessed a $350 conference setup fee. Cancellations will not be accepted if notice is received fewer than 5 business days before the event. For more information regarding administrative policies, complaints and cancellations, please contact us at 800.372.1033, or e-mail

Bloomberg BNA offers a hardship policy for CPAs and other tax and accounting professionals who wish to attend our live conference and seminars. Individuals must earn less than $50,000 annually in order to qualify. For individuals who are unemployed or earning less than $35,000 per year, a full discount off the price of registration for the program will be awarded. Individuals earning between $35,000 and $50,000 per year will receive a 50% discount off the price of the program. If an individual wishes to submit a case for hardship, he or she must contact Bloomberg BNA directly at


Please include the following information with your request: complete contact information, program for which a hardship reduction is being requested, requested amount for hardship reduction, and reason for applying for hardship. Please note that requests will not be considered until 30 days from the program date and that individuals may only apply for a hardship reduction once within a 12-month period. Bloomberg BNA reserves the right to make a final determination on a case-by-case basis. Our decision for granting a hardship is final and submission does not constitute acceptance.


Continental breakfasts, lunches, refreshment breaks, Bloomberg BNA Portfolio, and course materials in electronic format.