Public comments requested on FIRPTA tax incident to corporate reorganizations and distributions

The US Treasury Department and the Internal Revenue Service (IRS) have issued a notice requesting comments concerning IRS Notice 2006-46 (Announcement of Rules to be Included in Final Regulations under Section 89(d) and (e) of the Internal Revenue Code (IRC)).
The disposition of a US real property interest (USRPI) by a non-resident alien individual or foreign corporation is taxable under FIRPTA (Foreign Investment in Real Property Tax Act), codified as IRC section 897…