Foreign Pension Funds Could Back US Infrastructure
April 16, 2013, 6:36 PM EDT
Law360, New York (April 16, 2013, 6:36 PM EDT) -- On April 10, the White House issued the administration’s Fiscal Year 2014 Revenue Proposals. Contained in the infrastructure section is a proposed exemption for foreign pension funds from the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), which is found in Sections 897 and 1445 of the Internal Revenue Code of 1986, as amended (the “Code”).
FIRPTA is a withholding tax that applies to sales proceeds arising from a disposition of a U.S. real property interest by a non-U.S. owner. The buyer must withhold...