News & Analysis as of

Foreign Investment Registered Investment Companies (RICs)

Vinson & Elkins LLP

New Regulations Impact Tax Considerations for Foreign Investment in Real Estate

Vinson & Elkins LLP on

Key Takeaways- While foreign investors are typically taxed on gain from the sale of U.S. real property interests (which include interests in most equity REITs), they are generally exempt from tax on gain from the sale of...more

Proskauer - Tax Talks

New Repatriation Tax Relief for RICs and Foreign Income Guidance for REITs

Proskauer - Tax Talks on

On September 6, the Internal Revenue Service (“IRS”) released Revenue Procedure 2018-47 (the “RIC Rev Proc”) which provides that, a repatriation deemed to have been received by a registered investment company (a “RIC”) under...more

K&L Gates LLP

Permanent U.S. Withholding Tax Rules for Non-US Investors in RICs – A New Distribution Opportunity

K&L Gates LLP on

U.S.-registered investment companies (“RICs”) historically have had limited success attracting investments from non-U.S. investors, in large part due to U.S. withholding taxes on fund distributions. This has allowed funds...more

Morgan Lewis

New PATH Act Changes Rules for Foreign Investment in US Real Estate and for REITs

Morgan Lewis on

The PATH Act exempts certain foreign pension funds from taxation under FIRPTA and significantly modifies the tax rules applicable to REITs. On December 18, 2015 (Enactment Date), US President Barack Obama signed the...more

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