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2.43 MB
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Locations
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Quotes

Document Information

Type: Legal/tax memorandum or policy analysis brief
File Size: 2.43 MB
Summary

A legal or financial memorandum detailing changes to U.S. tax law following the enactment of the PATH Act (Protecting Americans from Tax Hikes Act). It explains how foreign pension funds can now invest in U.S. real estate (Raw Land, Mortgage Loans, Blocker Corps) and REITs with increased exemptions from FIRPTA taxes. The document outlines specific scenarios where capital gains are now exempt from U.S. income tax for foreign investors.

Organizations (1)

Name Type Context
House Oversight Committee
Bates stamp indicates document is part of House Oversight records (HOUSE_OVERSIGHT_026831)

Locations (6)

Location Context
Jurisdiction for tax laws and real estate location
Example jurisdiction for tax treaty
Example jurisdiction for tax treaty
Example jurisdiction for tax treaty
Example jurisdiction for tax treaty
Example jurisdiction for tax treaty

Key Quotes (2)

"Under the new law, the foreign pension fund's long-term or short-term capital gain is exempt from U.S. income tax and FIRPTA withholding because FIRPTA does not apply."
Source
HOUSE_OVERSIGHT_026831.jpg
Quote #1
"The Act provides all foreign investors (not just pension funds) can now own up to 10 percent of the stock of a publicly traded REIT without triggering FIRPTA tax."
Source
HOUSE_OVERSIGHT_026831.jpg
Quote #2

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