Nationwide  Specialists in foreign-seller real estate withholding
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Service · Form 8288-B

The IRS Withholding Certificate — Form 8288-B.

The single most powerful tool for foreign sellers facing FIRPTA. Done right, it reduces 15% of the gross sale price down to the actual tax owed on the gain — and keeps the difference in escrow rather than locked at the IRS for 12 to 18 months.

What it is

A pre-closing application that changes the math.

Form 8288-B is the IRS Application for Withholding Certificate. It's filed by (or on behalf of) the foreign seller before closing, asking the IRS to authorize a reduced FIRPTA withholding amount based on the actual expected tax on the gain — instead of the default 15% of the gross sale price.

The math difference is often dramatic. On a typical $750,000 sale where the seller's actual U.S. tax liability on the gain is $30,000:

  • !
    Without 8288-B: $112,500 withheld and sent to the IRS. Refund of $82,500 received 12–18 months later.
  • With 8288-B: ~$30,000 withheld. The remaining $82,500 stays with the seller at closing.

Same total tax. Vastly different cash flow.

When it makes sense

Almost always — but especially when:

The gain is small relative to sale price

Long-held property, depreciated rentals, modest appreciation.

  • 15% of gross can be 5–10× the actual tax
  • Largest dollar savings
  • Highest ROI on the engagement

You'll have a loss on the sale

No U.S. tax owed at all.

  • 8288-B can authorize $0 withholding
  • All proceeds clear at closing
  • Still requires Form 1040-NR the following year

Cash flow matters

You need the money for the next purchase, expenses, or repatriation.

  • Avoid the 12–18 month IRS hold
  • Funds released as escrow, not after refund
  • Plan around the 1% remittance excise tax
How the process works

From engagement to certificate.

1

Intake & gain modeling

No-charge intake call. We confirm FIRPTA applicability, gather basis documentation, model the expected gain or loss, and quote a flat fee in writing.

Day -90 to -60
2

ITIN coordination (if needed)

If the seller doesn't already have an ITIN, we file Form W-7 under Exception 4 (FIRPTA) — the specific exception designed for this case. IRS processing 7–12 weeks.

In parallel
3

Form 8288-B prepared & filed

Form prepared with full basis documentation, expected gain calculation, and proposed withholding. Filed with IRS Ogden along with the $1,510 IRS user fee (passthrough).

Day -60 to -30
4

Closing — funds escrowed

Property closes on schedule. The buyer's withholding agent (typically the title company) holds funds equal to the full statutory withholding in escrow rather than remitting to the IRS.

Day 0
5

IRS rules on the application

IRS Ogden processes the 8288-B and issues a Withholding Certificate, typically 60–90 days after filing. The certificate states the actual amount of withholding required.

Day +30 to +90
6

Forms 8288/8288-A filed; escrow released

Buyer remits the certified amount to the IRS within 20 days of the certificate ruling. The over-withheld difference is released from escrow back to the seller.

Day +90 to +110
Transparent fees

What this actually costs.

Flat fees. The IRS charges a separate $1,510 user fee for the 8288-B application, billed as a passthrough — the firm doesn't mark it up.

Form 8288-B Engagement

Engagement & consultation
FIRPTA applicability review, withholding-rate determination, gain/loss calculation, case setup. Non-refundable. Due at signing.
$250
ITIN application — Form W-7 (Exception 4)
If needed. Form preparation, ID certification, IRS submission. IRS processing 7–12 weeks.
$350 per seller
Form 8288-B Withholding Certificate preparation
1 / 2 / 3 sellers. Full preparation, IRS submission, follow-up with IRS Ogden, certificate retrieval.
$500 / $650 / $800 + $100 ea. add'l
IRS user fee (passthrough)
Required by the IRS for processing every Form 8288-B application. Paid by the firm and billed back as a separate line item.
$1,510 IRS
Closing package — Forms 8288 & 8288-A
After the certificate is issued, all withholding forms, wire instructions to the title company, and mailing to IRS Ogden.
$400 + $200 ea. add'l seller
Rush surcharge
For engagements beginning fewer than 10 business days before closing. Form 8288-B in this timeframe is generally not viable; we'd typically pivot to closing-package-only service.
$200

Combine the line items above for your specific transaction. We provide a fixed written quote at the end of the no-charge intake call — before any work begins.

Important details

Things to know before you start.

Timing matters

The 8288-B works best when filed 60–90 days before closing. Filed within 30 days, the IRS typically can't rule before the 20-day post-closing window expires — at which point withholding must be remitted normally and the application becomes a refund mechanism.

An ITIN is required

The IRS won't process Form 8288-B without a valid taxpayer ID for each seller. If you don't have an ITIN yet, we apply via Form W-7 Exception 4 in parallel — but the 7–12 week IRS processing time has to be factored into the schedule.

The escrow holder must agree

The buyer's withholding agent (typically the title or settlement company) must agree to hold the funds in escrow rather than remitting to the IRS at closing. This is standard practice with experienced title companies on FIRPTA transactions, but it's worth confirming early. If your title company is unfamiliar, we coordinate with them directly.

Section 899 may apply

Sellers from countries the U.S. has classified as imposing "unfair foreign taxes" on U.S. persons may face an additional Section 899 surcharge — 5 to 20 percentage points above the standard FIRPTA rate. We confirm country status at intake and reflect it in the 8288-B calculation.

Form 8288 January 2026 revision applies

The IRS now requires a separate Form 8288 for each disposition and a separate Form 8288-A for each foreign seller. Multi-seller transactions that previously used a single combined form now need per-seller forms — driving the per-seller fee structure above.

Get started

Ready to file?

A no-charge intake call confirms applicability, sets the schedule, and produces a written quote. Most engagements begin within 48 hours of the call.