How we handle your information.

FIRPTA Income Tax Withholding LLC (“we,” “us,” or “our”) operates the website at firptaincometaxwithholding.com and provides FIRPTA tax-compliance services to foreign sellers of U.S. real estate, their title agents, settlement attorneys, brokers, and buyers. This Privacy Policy explains what we collect when you interact with our website or engage our services, how we use it, and the rights you have over it.

This policy is written to align with U.S. federal preparer-confidentiality obligations (IRC §§ 6713 and 7216), the California Consumer Privacy Act (CCPA) as amended, and the EU General Data Protection Regulation (GDPR). It is not a substitute for legal advice.

1. What we collect

We collect only what you give us and what is necessary to perform the services you request. Specifically:

• Contact information you submit through our intake form: first and last name, email address, phone number, your role (foreign seller / title agent / broker / buyer / other), and the country of the seller’s tax residence.
• Transaction information you choose to share: property address, estimated sale price, planned closing date, requested service scope, and any notes you add (prior depreciation, 1031 history, related-party issues, etc.).
• Inquiry context: the page URL of your submission and the interface language you used. We do not collect any tracking cookies or third-party advertising identifiers.
• Service-delivery records: if you become a client, we collect what is needed to prepare your IRS filings (e.g., Form 8288, 8288-A, 8288-B, W-7, 1040 / 1040-NR), including IDs required by the IRS, signed engagement letters, and our work product. This is governed by your engagement letter, not this Privacy Policy.
• Network metadata: IP address and timestamp of submissions, recorded in an audit log used to investigate abuse and to debug delivery issues. We do not log browsing behavior across pages.

2. What we do not collect

• We do not use third-party analytics that profile visitors (no Google Analytics, no Meta Pixel, no advertising trackers).
• We do not use cookies for advertising or remarketing. Functional cookies (e.g., language preference) may be set by your browser; you can clear them at any time.
• We do not sell personal information to anyone, ever. We do not share it with marketers, data brokers, or affiliates.

3. How we use what you submit

• To respond to your inquiry and provide a written scope, fee quote, and timeline.
• To prepare and file IRS forms on your behalf if we become engaged.
• To send transactional follow-ups about your inquiry or case (e.g., confirmation emails, deadline reminders).
• To meet our own compliance obligations (records retention, audit response, AML / KYC where applicable).

4. Who we share information with

We share only with parties strictly necessary to deliver the services you requested:

• The Internal Revenue Service (IRS), when filing your forms on your behalf.
• Better Tax & Accounting, LLC, our credentialed coordinating accountant for U.S. tax returns (Forms 1040 and 1040-NR), where you have engaged that service.
• Sub-processors that operate our infrastructure: Render (web hosting), Netlify (website hosting), Resend (transactional email delivery), Cloudflare (DDoS / bot protection). Each is bound by its own published security and confidentiality terms.
• Law-enforcement or regulatory authorities only where required by court order, subpoena, or statute, and only the minimum required.

We are bound by federal preparer-confidentiality rules (IRC § 7216) once you are a client: we cannot disclose your tax-return information without your written consent, except as expressly permitted by Treasury Regulations.

5. How long we keep it

• Inquiry-stage data (a website intake submission that does not become an engagement): retained for 24 months, then deleted from our CRM, unless you ask us to delete it sooner.
• Client engagement records: retained for seven (7) years after the close of the engagement, in line with IRS recordkeeping requirements for tax preparers.
• Network audit logs: retained for 12 months.

6. Your rights

Subject to legal limits (e.g., we may need to keep some records to satisfy IRS retention rules), you have the right to:

• Know what we have collected about you.
• Access a copy of that information.
• Correct inaccurate information.
• Delete information that is no longer required for the service or by law.
• Opt out of any marketing communications. (Transactional emails about an active inquiry or case are not subject to opt-out while the case is open.)
• Lodge a complaint with a supervisory authority — for EU residents, your national data protection authority; for California residents, the California Privacy Protection Agency.

To exercise any of these rights, email office@firptaincometaxwithholding.com with “Privacy request” in the subject line. We respond within 30 days.

7. Security

Submissions to this website are protected in transit by HTTPS. Our platform enforces multi-factor authentication for staff accounts, encrypts data at rest, runs in U.S. data centers, takes encrypted off-site backups daily, and uses anti-abuse protection (Cloudflare Turnstile) on the intake form. We restrict access to client information to staff who need it to deliver the service.

No system is perfectly secure. If we detect a breach affecting your information, we will notify you by email within 72 hours, in accordance with applicable breach-notification laws.

8. International transfers

We are a U.S. company and our infrastructure operates in the United States. If you are submitting information from outside the U.S. (including the European Union, the United Kingdom, or Canada), you understand that your information will be transferred to and processed in the United States. We rely on the appropriate legal mechanisms for these transfers, including, where relevant, the EU–U.S. Data Privacy Framework and equivalent commitments.

9. Children

This website and our services are not directed at children under 16. We do not knowingly collect information from children. If you believe we have, please contact us and we will delete it.

10. Changes to this policy

We will update this policy as our practices or applicable law change. The “Effective” date at the top of this page indicates the most recent revision. Material changes will also be announced by email to active clients.

11. Contact

FIRPTA Income Tax Withholding LLC
Cleveland, Ohio · United States
office@firptaincometaxwithholding.com · 216-505-0717

Effective May 15, 2026. Version 1.0.