FIRPTA is a cash-flow problem disguised as a tax problem. How the 15% withholding works when a foreign owner sells U.S. property, the three ways to manage it, and when the §351 route earns its complexity.
The portfolio interest exception lets a foreign lender receive U.S. interest with zero withholding, no treaty required, if eight conditions are met at origination. The checklist, a worked example, and the failures that only surface in audit.
Entity choice, multi-state nexus, and the QSBS exit exclusion. The three tax decisions every U.S.-market entrant makes, usually in the wrong order, with 2025–2026 thresholds.