conveyance of real property interest owned later

If two or more persons are joint transferees of a U.S. Failures to withhold and pay over are subject to the liabilities set forth in paragraph (e) of this section. Amounts withheld must be reported and paid over in accordance with the requirements of paragraph (c) of this section. Neither the transferee's duty to withhold nor the amount required to be withheld is affected by the amount of cash to be paid by the transferee. real property interests are required to deduct and withhold a tax equal to 15 percent of the amount realized by the transferor if the transferor is a foreign person. Except as provided in paragraph (b)(2) and §§ 1.1445–2 and 1.1445–3, transferees of U.S. Finally, § 1.1445–7 provides rules concerning the treatment of a foreign corporation that has made an election under section 897(i) to be treated as a domestic corporation. Section 1.1445–5 provides rules concerning the withholding required under section 1445(e), while § 1.1445–6 provides for adjustments to the amount required to be withheld under section 1445(e). Section 1.1445–4 prescribes the duties of agents in transactions subject to withholding under either section 1445(a) or 1445(e). Section 1.1445–3 provides for adjustments to the amount required to be withheld by transferees under section 1445(a). Section 1.1445–2 provides for various situations in which withholding is not required under section 1445(a).

This § 1.1445–1 provides general rules concerning the withholding requirement of sections 1445(a), as well as definitions applicable under both section 1445(a) and 1445(e). Section 1445(e) provides special rules requiring withholding on distributions and certain other transactions by corporations, partnerships, trusts, and estates. real property interest from a foreign person must withhold a tax of 15 percent (10 percent in the case of dispositions described in paragraph (b)(2) of this section) from the amount realized by the transferor foreign person (or a lesser amount established by agreement with the Internal Revenue Service).

In general, section 1445(a) provides that any person who acquires a U.S. These regulations set forth rules relating to the withholding requirements of section 1445. real property interests by foreign persons: In general. § 1.1445-1 Withholding on dispositions of U.S.

Conveyance of real property interest owned later