My property is in a disregarded single-member LLC — who is the 'transferor' for FIRPTA, the LLC or me?
I hold a US rental in a single-member LLC that's disregarded for tax. When I sell or exchange it, who counts as the transferor for FIRPTA purposes — the LLC, or me the foreign owner? It matters for the certifications at closing. Can the LLC just certify it's a US entity and skip withholding, since it's a US LLC? That would be convenient, but it sounds too easy.
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