ARTICLE · 23 MARCH 2016

New Regulations Affect FIRPTA Filings

Holland & Knight

Explore more from Holland & Knight

The Protecting Americans from Tax Hikes Act of 2015 (the PATH Act), which was signed into law on December 18, 2015, made several changes to the U.S. federal income tax rules applicable to foreign persons...

United StatesTax

Author LinkedIn connections

Kevin. M. Hall is an Associate in our Ft Lauderdale office.

The Protecting Americans from Tax Hikes Act of 2015 (the PATH Act), which was signed into law on December 18, 2015, made several changes to the U.S. federal income tax rules applicable to foreign persons who own U.S. real estate and interests in U.S. real estate investment trusts (REITs). Given the significance of these recent changes, it would be easy to overlook a simple, but important, change made by regulations issued on March 7, 2016.¹These regulations change the address where many FIRPTA documents must be filed. This change applies to several FIRPTA filings, including:

a domestic corporation's determination regarding whether it is a U.S. real property holding corporation, which must be provided to a foreign shareholder and sent to the IRS after a foreign shareholder requests such a determination;²

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

QSBS, Eh? Canada’s New $15 Million Capital Gains Exemption

United StatesTax

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Latest Tax Updates: Investment Fund Scrutiny, Digital-asset Staking, And IRS-DOJ Authority

United StatesTax

McDermott Will & Schulte

IRS Installment Agreement vs. Offer In Compromise: Understanding Your Options For Resolving Tax Debt

United StatesTax

Eugene Voters Approve 2% Tax On Large Retailers To Fund Clean Energy Programs

United StatesTax

Greenberg Traurig

New York City Issues Guidance On OBBBA Decoupling Adjustments For Business Taxes

United StatesTax

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

Comparative Guide

Tax Disputes

Comparative Guide

Tax

See more popular content from

Tax

IRS Suspends Penalties For Highway Use Of Dyed Diesel Fuel

President Trump's Executive Order 14435 directs the IRS to provide temporary relief from federal tax penalties on dyed diesel fuel used for highway purposes. The relief, retroactive to October 1, 2026, suspends enforcement and recordkeeping requirements while the Treasury Department explores options to eliminate deferred tax obligations entirely.

United StatesTax

Holland & Knight

GENIUS Act Crypto Tax Guide 2025-2026: What US Investors, Businesses, And Taxpayers Need To Know About The New Stablecoin Law, Form 1099-DA, And Digital Asset Regulation

The United States cryptocurrency regulatory landscape has undergone its most dramatic transformation in history. The signing of the GENIUS Act into law on July 18, 2025 — the first comprehensive federal crypto statute ever enacted — marks a before-and-after moment for American digital asset law.

United StatesTax

Rotfleisch & Samulovitch P.C.

The First Round Of Saver’s Match Guidance Is Here

The Treasury Department and IRS have released Notice 2026-48, providing the first comprehensive guidance on SECURE 2.0's new Saver's Match program. This federal matching contribution for low- and moderate-income retirement savers introduces complex implementation challenges, including how to route taxpayer matches directly to retirement plans and IRAs. The Notice addresses eligibility requirements, income limits, contribution types, and delivery mechanisms while requesting public comments on operational app

United StatesTax

Groom Law Group, Chartered

IRS Updates Guidance On The “No Tax On Overtime” Deduction

On August 6, 2026, the IRS released Fact Sheet 2026-13, an expanded set of FAQs on the qualified overtime compensation deduction created by the One, Big Beautiful Bill Act. The update replaces January’s FS-2026-01 and marks the shift from 2025’s transition relief to the full compliance framework now in effect.

United StatesTax

California's Proposed Billionaire Tax: What You Need To Know

California's Proposition 40 would impose a one-time excise tax of up to 5 percent on billionaires' worldwide net worth, measured as of December 31, 2026, but based on residency as of January 1, 2026. The measure faces significant legal challenges and could be nullified by competing ballot initiatives that have also qualified for the November 2026 ballot.

United StatesTax

Holland & Knight

New Jersey Codifies The ABC Test: What The Independent Contractor Regulations Mean For Your Business

Partner Scott H. Novak specializes in tax law, focusing on tax controversy, trusts and estates, planning, and transactional tax matters. His extensive experience encompasses federal, state, foreign, and employment tax issues, handling everything from non-filing cases to complex audits, estate planning, and settlements with tax authorities.

United StatesTax

Scarinci Hollenbeck LLC

California Expands Sales And Use Tax To SaaS And Certain Digital Products Starting 1 January 2027

California is implementing a major tax policy shift that will subject software-as-a-service, remotely accessed software, and digital products to sales and use tax beginning January 1, 2027. The California Department of Tax and Fee Administration has proposed emergency regulations establishing sourcing rules, a $5 million threshold that shifts tax liability from retailers to purchasers, and key exemptions for custom software and certain service-based digital products.

United StatesTax

Tax Strategies: Selling Your S Corporation Business

Selling an S corporation involves complex tax and legal considerations that can significantly impact after-tax proceeds. This comprehensive analysis examines stock sales versus asset sales, IRC Section 338(h)(10) elections, F reorganizations, and other transaction structures, revealing how different approaches affect both sellers and buyers through detailed tax modeling and strategic planning insights.

United StatesTax

Washington’s Millionaires’ Tax Heads To November Ballot

Washington voters will decide the future of the state’s new 9.9% tax on annual taxable income above $1 million after a repeal initiative qualified for the November ballot.

United StatesTax

Louisiana Department Of Revenue Provides Guidance Regarding Recent Sales Tax Changes

Last week, the Louisiana Department of Revenue (the "Department") issued guidance regarding recent sales and use tax law changes. The Department issued Revenue Information Bulletin No. 25-023...

United StatesTax