On April 25, 2024, the Department of the Treasury and the Internal Revenue Service issued final regulations (T.D. 9993) (the “Final Transfer Regulations”) regarding the transfer election for certain tax credits by eligible...more
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
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