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Private Letter Rulings Real Estate Investments

Vinson & Elkins LLP

IRS Releases Favorable Guidance on the Tax Treatment of Payments to REITs and MLPs for Subsurface Carbon Dioxide Storage

Vinson & Elkins LLP on

Along with the broader market, real estate investment trusts (“REITs”) and publicly traded partnerships, frequently referred to as master limited partnerships (“MLPs”), have increasingly embraced the principles of...more

Freeman Law

That’s Not Income! | REIT’s Section 481(a) Adjustments Not Considered Gross Income

Freeman Law on

Mark Twain once said, “Buy land, they’re not making it anymore.” Perhaps it is this sentiment (along with returns on investments) that has led to the popularity of real estate investment trusts...more

Vinson & Elkins LLP

IRS Changes Tack on Rents Paid Under Escalation Clause as REIT Qualifying Income

Vinson & Elkins LLP on

In a ruling that may impact real estate investment trusts (REITs) with leases that have percentage or contingent rent clauses, the IRS recently changed its prior position that rent paid under a formulaic rent escalation...more

Miles & Stockbridge P.C.

IRS Limits Ability of REITs to Obtain Private Letter Rulings on Tax-Free Spin-Off Transactions

Miles & Stockbridge P.C. on

In the recently released Revenue Procedure 2015-43, the Internal Revenue Service (“IRS”) announced that it no longer will issue private letter rulings with respect to certain tax-free spin-offs where, immediately after the...more

Lowndes

Ski Lift Towers Held to Be Good REIT Asset

Lowndes on

In order to qualify for the tax advantages available for real estate investment trusts (“REITs”), the majority of a REIT’s assets must qualify as “real property”. As the areas that REITs are investing in continue to grow, we...more

McDermott Will & Emery

Proposed Regulations Clarify Definition of “Real Property” for Real Estate Investment Trusts

McDermott Will & Emery on

On May 9, 2014, the Internal Revenue Service and U.S. Department of the Treasury issued proposed regulations (the Proposed Regulations) under Section 856 of the Internal Revenue Code (the Code) to clarify the definition of...more

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