In our December 3, 2015 REIT Alert we suggested that the Prop Co/Op Co structure implemented by a tax-free REIT spin-off may not be dead. On December 7, 2015 House Ways and Means Committee Chairman, Kevin Brady (R-TX)...more
In recent years, a number of public companies have sought to unlock the value embedded in their corporate real estate assets by separating the real estate and other assets into two separate entities – a so-called PropCo/OpCo...more
In issuing IRS Notice 2015-59 and Rev. Proc. 2015-43 last week, the IRS intentionally created significant market uncertainty about the viability of “PropCo/OpCo” spin-offs as part of the PropCo’s REIT conversion (e.g., where...more