Installments, multi-seller deals, and hard cases.

When a foreign seller takes back a note instead of cash at closing — installment sale, seller financing, or any deferred-payment structure — FIRPTA's mechanics get unusual fast.

Special rules apply:

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  Withholding generally applies to each installment payment as it is received — not just at closing — and the buyer must file a separate Form 8288 for each payment.
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  The seller is generally responsible for ensuring withholding occurs on each payment, since the buyer may not understand their continuing obligation after closing.
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  A single Form 8288-B at closing can sometimes set the withholding for all future installments, but the structure has to be designed correctly upfront.
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  The 1% remittance excise tax under IRC §4475 potentially applies to each installment payment that's then transferred outside the U.S. — adding up over multi-year notes.

If your transaction includes seller financing or installment payments, tell us at intake. We scope the engagement around the full payment stream, not just the closing.

Standard engagement fees ($250) and per-seller form preparation fees apply. Beyond that, hard-case engagements are scoped individually because the variance is too wide for a flat-rate quote:

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  Installment sale Form 8288-B engagement: typically $750–$1,200 firm fee plus the $1,510 IRS user fee, depending on the note structure and whether multi-year monitoring is included.
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  Foreign entity sellers: typically $750–$1,500 firm fee for the Form 8288-B, depending on entity complexity.
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  Late-filing rescues: billed hourly at $300/hour, capped at the projected penalty exposure. We don't take engagements where our fee approaches the penalty we're trying to mitigate.
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  Multi-property dispositions: per-property line items combined into a single engagement with volume discount.

Every engagement is quoted in writing after a no-charge intake call. We don't take cases we can't help, and we tell you so on the call.