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WHEN PARTNERSHIPS DISPOSE OF US REAL PROPERTY INTERESTS (usrpis), the presence of nonresident alien partners will
REQUIRE THAT THE FOREIGN PARTNERS HAVE THEIR US INCOME TAX FILING REQUIREMENTS SATISIFIED BY PARTNERSHIP
REQUIRE THE FOREIGN PARTNERS MAKE A CAPITAL CONTRIBUTION TO THE PARTNERSHIP FOR THE FIRPTA TAX
REQUIRE WITHHOLDING WHICH WILL DIFFER WHETHER PARTNERSHIP IS DOMESTIC OR FOREIGN
REQUIRE A GAIN ALLOCATION TO THE DOMESTIC PARTNERS ONLY
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