On August 19, the IRS announced guidance providing relief for certain non-U.S. corporations redomiciling into the United States. Notice 2025-45 (the “Notice”) introduces an exception to the general ...
FIRPTA requires a non-U.S. person disposing of a U.S. real property interest (a “USRPI”) to recognize gain or loss on such disposition as if the non-U.S. person were engaged in a trade or business ...
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