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Final Regulations Issued on Domestically Controlled REIT Determinations and Energy Credit Transfers

Two sets of recently finalized regulations provide guidance for REITs. Key Points: - Final FIRPTA regulations provide rules for determining whether a REIT is domestically controlled, including a look-through rule for...more

Considerations for REITs in Adopting a Poison Pill in Response to the COVID-19 Crisis

REIT management and boards of directors should review their defensive profile and consider whether to prepare a rights plan. Key Points: ..Unprecedented market volatility and investor uncertainty due to the coronavirus...more

IRS Relaxes Stock Dividend Safe Harbor for Publicly Offered REITs and RICs in 2020

Recent IRS guidance reduces the minimum aggregate amount of cash required for certain distributions of stock and cash to qualify for the dividends paid deduction. In order to enhance liquidity of publicly offered real...more

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more

Qualified Opportunity Funds: Investment and Structuring Considerations

Recent guidance from Treasury clarifies fundamental aspects regarding the investment of deferred capital gains in QOFs. Key Points: ..Investors in qualified opportunity funds may derive significant tax benefits in the...more

US Tax Reform: Key Business Impacts, Illustrated With Charts and Transactional Diagrams

Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context. Key Points: ..The legislation alters fundamental aspects of US business taxation...more

Congressional Tax Reform Proposals: Businesses Will Need to Rethink Key Decisions

Potential legislation would significantly affect businesses across a variety of sectors. Key Points: ..US House and Senate have each passed comprehensive tax reform legislation. ..Proposals would alter fundamental...more

IRS Provides Guidance on Stock Distributions for Publicly Offered REITs and RICs

Revenue procedure sets forth requirements for ensuring certain stock distributions are treated as property distributions eligible for dividends paid deduction. On August 11, 2017, the Internal Revenue Service (IRS)...more

Treasury Department Issues Final Regulations on Real Property Definition for REIT Purposes

Final regulations establish analytical framework for determining whether assets qualify as real property for purposes of the REIT rules. On August 31, 2016, the Treasury Department and the Internal Revenue Service (IRS)...more

Congress Enacts Significant Changes to the REIT and FIRPTA Rules

Changes include restrictions on tax-free REIT spinoffs and other reforms generally favorable to REITs and non-US investors in US real estate. On December 18, 2015, President Obama signed into law the Protecting Americans...more

New Treasury Regulations Make it Easier to Issue Tack-On Bonds or Loans

On September 12, 2012, the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) which make it easier to issue fungible tack-on debt instruments in situations where either the original debt...more

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