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26 CFR § 1. 897-2 - United States real property holding corporations. U S real property holding corporation status is important for determining whether gain from the disposition by a foreign person of an interest in a domestic corporation is taxable Such status is also important for purposes of the withholding and reporting requirements of sections 1445 and 6039C
U. S Real Property Holding Corporations (USRPHC) What is a USRPHC? A U S Real Property Holding Corporation, (USRPHC), is corporation where the fair market value of the US real property interests held by the corporation on any applicable determination date equals or exceeds 50% of the sum of the fair market values of its US real property interests, Interest in real property located outside the
Definitions of terms and procedures unique to FIRPTA U S Real Property Holding Corporation (USRPHC) In general, a corporation is a U S real property holding corporation if the fair market value of the U S real property interests held by the corporation on any applicable determination date equals or exceeds 50 percent of the sum of the fair market values of its:
What Is a Real Property Holding Company for Tax Purposes? A Real Property Holding Company (RPHC) is a designation for a corporation with substantial holdings in U S real estate This classification is a component of U S tax law designed to ensure that foreign investors are taxed on income they derive from U S real property
UNDERSTANDING U. S. TAXATION OF FOREIGN INVESTMENT IN REAL PROPERTY A domestic corporation will be considered a USRPHC where the FMV of its USRPIs equals or exceeds 50% of the FMV of all its interests in real property (including U S real property and real property outside the United States) as well as any other assets used or held for use in a trade or business
FIRPTA Planning and U. S. Real Property Holding Corporations What Qualifies as a U S Real Property Holding Corporation (USRPHC)? A corporation is considered a USRPHC if the value of its U S real property interests equals or exceeds the value of all of its real property and business assets combined
U. S. Real Property Holding Corporation - Income Taxes - Tax Based on . . . A domestic corporation will be considered a USRPHC if the fair market value of its USRPIs equals or exceeds 50 percent of the sum of the fair market values of its USRPIs, its interests in real property located outside the United States, and other assets used or held for use in a trade or business (IRC § 897 (c) (2) and Reg §1 897-2 (b))
Plan Ahead to Reduce (or Eliminate) U. S. Withholding Tax when Selling . . . A U S real property interest (“USRPI”) generally includes land, buildings, growing crops and timber, and mines, wells and other natural deposits (including oil and gas properties and mineral deposits) located in the United States and equity interests in a “United States real property holding corporation” (“USRPHC”) as well as