r and has a "tax home" in the United States in which case the nonresident alien individual will be subject to a 30% tax on his capital gains. Under the Foreign Investment in Real Property Tax Act, referred to as "FIRPTA," distributions that are attributable to gain from the sales by us of USRPIs and paid to a non-U.S. sh

'S OFFICE FOR INFORMATION. zzs (i) FIRPTA TAX WITHHOLDING: Seller shall inform Buyer in writing if Seller is a 'foreign person' as defined by 220 the Foreign Investment in Real Property Tax Act ('FIRPTA'). Buyer and Seller shell comply with FIRPTA, 227 which may require Seller to provide additional cash at Closing. If

connected income, and hence such non-U.S. person could be subject to U.S. Federal income tax and branch profits tax on the sale or exchange. Under the Foreign Investment in Real Property Tax Act of 1980, or "FIRPTA," provisions of the Code, certain non-U.S. persons are subject to U.S. tax in the same manner as U.S. pers

purposes as effectively connected income, and hence such non-U.S. person could be subject to U.S. Federal income tax on the sale or exchange. Under the Foreign Investment in Real Property Tax Act of 1980, or "FIRPTA," provisions of the Code, certain non-U.S. persons are subject to U.S. tax in the same manner as U.S. pers