Two sets of recently finalized regulations provide guidance for REITs.
Key Points:
- Final FIRPTA regulations provide rules for determining whether a REIT is domestically controlled, including a look-through rule for...more
Recent IRS guidance reduces the minimum aggregate amount of cash required for certain distributions of stock and cash to qualify for the dividends paid deduction.
In order to enhance liquidity of publicly offered real...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects.
On November 26, 2018, the Treasury and...more
12/20/2018
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Interest Payments ,
Internal Revenue Code (IRC) ,
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Partnerships ,
Proposed Regulation ,
REIT ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
The new guidance is significant given the popularity of debt exchanges as a monetization technique in conjunction with spin-offs.
On October 3, 2018, the Internal Revenue Service (IRS) published Revenue Procedure 2018-53,...more