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  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

IRS Final Regulations on FIRPTA Exemption for Qualified Foreign Pension Funds

Modification of the 85% Test, New and Revised Definitions, Withholding Rules, and More

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
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Description

FIRPTA imposes a tax and withholding regime on gain realized on dispositions of U.S. real property interests by nonresidents or non-U.S. persons. However, “qualified foreign pension funds” are generally not subject to the tax and withholding requirements. On Dec. 29, 2022, the IRS finalized regulations which clarifies the rules for determining the qualification for the FIRPTA tax exemption under Section 897(l) for qualified foreign pension funds. In addition, the final regulations provide additional detail on the certification and documentation requirements for withholdings under Sections 1445 and 1446. Tax practitioners must have a complete understanding these final regulations to minimize any adverse tax implications for their foreign pension fund clients.

In light of the final regulations, tax counsel must be able to determine what entities qualify for the exemption, understand the information reporting requirements, withholding tax and certification rules, and other critical items.

Listen as our panel discusses key provisions of the final regulations, modifications to the FIRPTA exemption, the 85 percent test, new and revised definitions, changes and application of the withholding rules, and other key issues.

Presented By

Billy Abbott
Partner
O'Melveny & Myers LLP

Mr. Abbott advises clients on tax matters in the context of private and public mergers and acquisitions, the formation of, and investments in, private equity funds, partnerships and limited liability companies (LLCs), debt and equity securities issuances, and large-scale syndicated credit facilities.

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Ilene W. Fine
Managing Director, International Tax Services
PwC US, LLP

Ms. Fine is an international tax director in the National Tax Services Practice of PricewaterhouseCoopers and specializes in the inbound international tax practice.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Tuesday, March 21, 2023

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Overview of FIRPTA
  2. Final qualified foreign pension funds regulations
  3. Withholdings under Sections 1445 and 1446
  4. Reporting requirements
  5. Best practices for tax counsel and advisers

The panel will discuss these and other key issues:

  • Significant provisions and challenges of the final IRS qualified foreign pension funds regulations, including the 85 percent test
  • Application of FIRPTA to the transfer of U.S. real property by nonresidents or non-U.S. persons
  • Navigating the certification and documentation requirements for withholding under Secs. 1445 and 1446
  • Best practices and pitfalls to avoid for tax counsel and advisers to acquire the FIRPTA tax exemptions

Learning Objectives

After completing this course, you will be able to:

  • Recognize significant tax provisions and challenges of the final IRS qualified foreign pension funds regulations
  • Understand the application of FIRPTA to the transfer of U.S. real property by nonresidents or non-U.S. persons
  • Ascertain the certification and documentation requirements for withholdings under Secs. 1445 and 1446 under the final regulations
  • Understand how to determine what entities qualify for the FIRPTA tax exemption
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules for U.S. taxpayers owning or receiving payments from non-US retirement accounts; supervisory authority over other preparers/accountants. Specific knowledge and understanding of basic reporting requirements for U.S. taxpayers with foreign retirement account interests; familiarity with FBAR, FATCA and For 3520 filings.

BARBRI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .