Tax Sharing Agreements This allows companies leaving the tax group (for example on a sale to a third party) to rely on the 'clear exit' rule which limits that leaving company's exposure to the joint and several tax liabilities of the whole group.
This law requires that the buyer withhold at least 15 percent at closing as a deposit against the seller's tax liability, which is intended to serve as an estimate of the capital gains taxes due. However, FIRPTA still applies even when the property is sold at a loss.