US income taxation of foreign investment in U.S. real estate

Journal
Bulletin for International Taxation 2001 (Volume 55), No. 9
This article examines the US taxation of operating income derived from US real estate activities and the US taxation of the gain on disposition. In most cases, this tax treatment must be measured by reference to both US domestic tax law and the applicable tax treaty. The provisions of the Foreign Investment in Real Property Tax Act (FIRPTA) are considered as well.