id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-305	Taylor, Willard B.	Suppose FIRPTA Was Repealed	2022	44	.pdf	application/pdf	21309	818	54	The treatment of foreign corporations under FIRPTA (for example, the recognition of gain by a foreign corporation that distributed an interest in USRP to a shareholder), because it did not conform to the treatment of U.S. corporations, could also be seen as violating the general anti-discrimination of provisions of U.S. tax treaties.66 FIRPTA addressed this by allowing a foreign corporation to elect to be a U.S. corporation.67 [Vol. 14:1 gross rental income.21 Apart from the withholding tax on non-effectively connected rents or royalties, the tax on U.S. real property income or gain was, before FIRPTA, self-assessed.	cache/ftr-305.pdf	txt/ftr-305.txt