Quotes from IRS Publication 515:

"Per diem for subsistence paid by the U.S. Government (directly or by contract) to a nonresident alien engaged in a training program in the United States funded by the U.S. Agency for International Development are not subject to 14% or 30% withholding. This is true even if the alien is subject to income tax on those amounts." (Pub. 515, pg. 33, "Per Diem Paid by the U.S. Government")

"U.S. real property interest (USRPI). A withholding agent may also be responsible for withholding if a foreign person transfers a USRPI to the agent, or if it is a corporation, partnership, trust, or estate that distributes a USRPI to a shareholder, partner, or beneficiary that is a foreign person. See U.S. Real Property Interest, later.” (Pub. 515, pg. 4, “U.S. Real Property)

-(cont.) “(thus) If the transferor is a foreign person and the transferee fails to withhold, the transferee may be held liable for the tax. For cases in which a U.S. business entity, such as a corporation or partnership, disposes of a U.S. real property interest, the business entity itself is the withholding agent.” (For more information, please refer to: irs.gov/individuals/international-taxpayers/firpta-withholding

Publication 515 and related regulations are very complicated and confusing. We do not, and can not provide any tax advise on these regulations. We are never responsible for any tax liabilities or obligations you may incur, regardless or the reason, or who caused the liability to occur.

Please consult your tax advisor or the IRS about all aspects of payments to foreign persons, including Publication 515, IRS forms W-9, W-8, Form 1042-S and all related subjects.