The taxation of property transfers to foreign entities

Article Abstract:

The Taxpayer Relief Act of 1997 replaced former IRC sections 1491 through 1494 with new provisions generally requiring the recognition of gain on transfers of appreciated property to foreign entities. The new provisions do not include the criticized excise tax, information reporting rules, and penalty provisions contained in the former law. The operation of the new provisions will be clarified when the IRS issues regulations.

Laws, regulations and rules, International business enterprises, Multinational corporations, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation), Transfer (Law)

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Effect of the U.S.-Canada treaty protocol on the taxation of real property holding corporations

Article Abstract:

The fourth protocol to the US-Canada Income Tax Convention was signed on Jul 29, 1997, and resolves taxation issues for real property interests of holding companies. Foreign taxpayers once needed to pay US income tax on gains from some investments in US real property, and the fourth protocol establishes the right of each country to tax its residents on capital gains and pay only that country's taxes.

Canada, International aspects, Holding companies, Real estate, Real property

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