Ideas & Insights

Final section 864(c)(8) regulations clarify rules for foreign partners with ECI from transfers of partnership interests.

Global investors in U.S. real estate need to consider how their investment structure can affect income taxes and reporting requirements.

When entering the U.S. tax system through investment or relocation, a nonresident faces unique tax reporting and filing obligations.

Final regs update some categories of subpart F income, treatment of foreign-held U.S. property in transactions that involve partnerships.