The US Department of Treasury recently released final regulations providing guidance on the exception from taxation under the Foreign Investment in Real Property Tax Act of 1980 for “qualified foreign pension funds” under...more
The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. Final regulations under Section 897 regarding the exemption...more
New guidance from the Internal Revenue Service will allows RICs and REITs to retain more capital by distributing less cash to shareholders in certain stock distributions—welcome relief during the current economic volatility...more
The IRS has issued Revenue Procedure 2017-45, which provides that certain distributions of stock by a publicly offered RIC or publicly offered REIT made pursuant to a “cash or stock election” will be treated as a taxable...more
The regulations affect both real estate investment trusts (REITs) and regulated investment companies (RICs) that receive appreciated property from a C corporation in a so-called “conversion transaction.”...more
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
1/6/2016
/ FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Pension Funds ,
Protecting Americans from Tax Hikes (PATH) Act ,
Real Estate Investments ,
Registered Investment Companies (RICs) ,
REIT ,
Securities and Exchange Commission (SEC) ,
Shareholders ,
Spinoffs