News & Analysis as of

C-Corporation Real Estate Investment Trust

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Proskauer - Tax Talks

Final Regulations on Domestically Controlled REITs

Proskauer - Tax Talks on

On April 24, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations on the definition of “domestically controlled” real estate investment trusts (“REITs”)...more

Goodwin

IRS Finalizes Regulations for Domestically Controlled REITs and other Qualified Investment Entities

Goodwin on

On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more

Bilzin Sumberg

Final Treasury Regulations Implement a 10-Year Transition Rule for Existing Domestically Controlled REITs

Bilzin Sumberg on

The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) have recently issued final regulations (the “Final Regulations”) that significantly impact the determination of whether a real...more

King & Spalding

Treasury Issues Final Regulations Addressing “Domestically Controlled” REIT Status

King & Spalding on

On April 25, 2024, the IRS and Treasury issued final regulations (the “Final Regulations”) addressing whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute a...more

Mayer Brown

US Treasury Releases Final Regulations Addressing Domestic Control Determinations Under FIRPTA

Mayer Brown on

On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the...more

Cozen O'Connor

Treasury Issues Game-Changing Final Regulations on Domestically Controlled REIT Status

Cozen O'Connor on

The United States Department of Treasury issued final regulations (Final Regulations) that arguably change the test (DC Test) for determining whether a REIT is a domestically controlled qualified investment entity (DC-REIT)....more

Vinson & Elkins LLP

IRS Releases Final Regulations Impacting FIRPTA Exemption for Domestically Controlled REITs

Vinson & Elkins LLP on

On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more

King & Spalding

Proposed Regulations Would Impact Taxation of Investment in U.S. Real Estate by Non-U.S. Investors

King & Spalding on

On December 29, 2022, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) addressing (1) whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute...more

Holland & Knight LLP

Proposed Treasury Regulations Reverse Guidance on Domestically Controlled REITs

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The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more

Paul Hastings LLP

New Treasury Guidance on Sovereign Wealth Funds, Qualified Foreign Pension Funds, and REITS and RICs

Paul Hastings LLP on

On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

Bracewell LLP

Utilizing REITs for Midstream Assets

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The real estate investment trust (REIT) has been a preferred vehicle for investment in income producing real estate portfolios. The REIT provides investors with many federal income tax benefits associated with C-corporations,...more

McDermott Will & Emery

Weekly IRS Roundup June 3 – 7, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019. June 4, 2019: The IRS issued a news release noting that it granted tax relief...more

Latham & Watkins LLP

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

Latham & Watkins LLP on

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

Proskauer - Tax Talks

U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations

Proskauer - Tax Talks on

On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Guidance for Opportunity Zone Funds Clarifies Important Issues, Leaves Door Open to Additional Guidance

The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more

McGuireWoods LLP

OIRA Updates Unified Agenda for Spring 2018

McGuireWoods LLP on

The Office of Information and Regulatory Affairs has updated its Unified Agenda of Regulatory and Deregulatory Actions for Spring 2018, providing a comprehensive look at the federal agencies’ rulemaking plans in the...more

Perkins Coie

Private Company Tax Planning Opportunities for 2018

Perkins Coie on

The Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act) and the recent taxpayer victory in the U.S. Tax Court’s Lender Management, LLC decision have created important planning opportunities for both our closely held and...more

Proskauer - Tax Talks

U.S. Senate Passes Its Version of the Tax Cuts and Jobs Act (H.R. 1); Descriptions of the Bills Passed in the House and Senate and...

Proskauer - Tax Talks on

In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more

King & Spalding

Early Takeaways for REITs from Tax Reform Season

King & Spalding on

After months of being communicated through vague frameworks and political talking points, Republican tax reform proposals have finally been unveiled in legislative language. Earlier this month, H.R.1, the Tax Cuts and Jobs...more

Lowndes

Treasury To Repeal/Revise 8 Burdensome Regs

Lowndes on

As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...more

Holland & Knight LLP

Treasury Dept. Identifies 8 "Significant Tax Regulations" for Review to Reduce Burden

Holland & Knight LLP on

The U.S. Department of the Treasury announced on July 7, 2017, in Notice 2017-38 (the Notice) that it has identified as "significant tax regulations" eight sets of U.S. federal tax regulations that were issued between Jan. 1,...more

Proskauer - Tax Talks

IRS Issues Final Regulations on REIT and RIC Conversion Transactions

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The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing from ten years to five years the recognition period for the corporate-level tax...more

Lowndes

Recent Developments in Partnerships and Real Estate 2017

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The IRS released a flurry of new rules as the Obama administration came to a close. The attached presentation provides an overview of many of these developments in the partnership and real estate tax area, including a...more

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