Proposed CFIUS Regulations Sweep in Foreign Investment in Real Estate Transactions; Comments Due October 17

Miles & Stockbridge P.C.

Banks, builders, developers and all those active in commercial real estate, particularly in Maryland, D.C., and Virginia, should be closely following proposed new Treasury Department rules governing foreign investment in real estate. Those rules may greatly complicate commercial real estate transactions in these states, especially transactions in real property near military installations.  

Depending on the final wording of certain key provisions, these rules may sweep in far more transactions than Congress or the Treasury Department intended, transactions without any plausible effect on national security. Comments pointing out these potential problems are due by October 17, and will be important to focus national security reviews on foreign real estate investments that raise plausible national security concerns. At the same time, more focused regulations are needed to avoid adding needless delay and expense to the many more commercial real estate transactions that pose no realistic security issues.

I.    Background:

On September 17, 2019, the U.S. Department of the Treasury published proposed regulations (the “Proposed Regulations”) implementing certain provisions of the Foreign Investment Risk Review Modernization Act (“FIRRMA”). The Proposed Regulations would expand the jurisdiction of the Committee on Foreign Investment in the United States (“CFIUS”) to cover non-controlling foreign investment in real estate transactions in close proximity to certain military installations (Proposed New Provision, 31 C.F.R. Part 802), 84 Fed. Reg. 50214 (Sept. 24, 2019), and foreign investment in certain U.S. business (Proposed Amendments to 31 C.F.R. Part 800), 84 Fed. Reg. 50174 (Sept. 24, 2019).  

CFIUS is an interagency committee, chaired by the Secretary of the Treasury, and tasked with the discretionary review of certain foreign investments in the U.S. and their potential national security risk. While CFIUS originally had the authority to review transactions that resulted in foreign control of U.S. business, FIRRMA expanded that authority to include foreign investments in covered real estate transactions and non-controlling foreign investments in U.S. businesses involved in critical technology, critical infrastructure, or sensitive personal data. This alert focuses on the Proposed Regulations regarding real estate transactions and the potentially significant impact they would have on land deals and real estate financing especially in the Maryland-DC-Virginia area.

II.    Foreign Investment in Real Estate in Maryland, DC, and Virginia

Covered Real Estate

Land in Close Proximity to Many Area Military Installations. The proposed regulations identify twenty-seven military installations in Maryland, DC, and Virginia, where foreign investment in real estate in “close proximity” (i.e. one mile) may trigger an elaborate interagency review and prohibition or modification of the transaction. That review would include a searching federal government inquiry into the foreign investors and their funding sources. The covered installations in the mid-Atlantic include Fort Meade and Fort Detrick in Maryland, the Norfolk Naval base in Virginia, and over a dozen locations in the Washington, D.C. area, including the Pentagon in Arlington, Virginia. 


Rural Real Estate within One Hundred Miles of Aberdeen Proving Ground or Patuxent Naval Air Station. In addition, a literal reading of the regulation would require that for the Patuxent Naval Air Station and the Aberdeen Proving Ground, both in Maryland, foreign investment in rural real estate within a one hundred mile radius may trigger such reviews. Because most of the nearby areas are defined as urban by the Census Bureau, and because such areas are exempt from the review at distances greater than one mile from the military installation’s boundary, there will be considerable uncertainty as to exactly what land is in fact subject to CFIUS review. This problem will be particularly acute given the 100 mile radius stated in the regulations and the urban definition of most of the area included in the resulting circles. It seems unlikely that the Treasury Department in fact intends so wide a sweep, but changes will be needed in the regulatory language to address that overreach. Real estate transactions at locations within one mile of Aberdeen and the Patuxent Naval Air Station are subject to CFIUS review if there is foreign investment in them, just as is the case with the other listed military bases.

Major Ports and Airports. The Proposed Regulations also define “covered real estate” to include real estate that is located within or will function as part of an airport or marine port. This will include the ports of Baltimore and Hampton Roads (also known as Ports of Virginia) as well as BWI, Reagan, and Dulles Airports, as well as Blackstone Army Air Field at Fort Pickett, Virginia. For ports and airports, the reviews include investments in the infrastructure or operations of such ports and airports, including transactions defined as concessions granted by governmental authorities for such infrastructure or operations (other than retail).

Coastline Development with Docks and Related Amenities. Finally, the Proposed Regulations cover offshore ranges located within certain military ranges located from the mean high water mark seaward of the coastline out to twelve nautical miles offshore. Specifically, CFIUS has named the Virginia Capes Operating Area and Virginia Capes Range Complex, an operating area and an offshore range that extend the length of Delaware, Maryland, Virginia and North Carolina Atlantic coasts. 84 Fed. Reg. 20542, Appendix A, Part 4. This designation could have a significant impact on offshore wind farms and on related onshore infrastructure. It may also adversely affect coastal development with docks and similar maritime amenities extending into the Atlantic Ocean, as might be the case for foreign investment or financing of a luxury golf resort with such maritime amenities. 

Exemptions for Certain Kinds of Real Estate Transactions

As noted, the statute – and the proposed regulations – exempt single family housing units from CFIUS reviews as well as leases in multi-tenant commercial buildings. But there are exceptions to the exemptions, exceptions which will require further clarification in order to avoid needless confusion and expense in the residential and commercial real estate markets near military bases.   

The general rule is that foreign real estate investment (other than single family housing units and leases in multi-tenant office buildings) will be subject to possible CFIUS review if the location is within one mile of one of the listed military installations. Thus, for example, the impending Amazon investment in its second headquarters near the Pentagon would be subject to such review if there is significant foreign investment in that development, since some of that land is within one mile of the Pentagon. 

Exemptions for Investors from Certain Countries

The Proposed Regulations allow CFIUS to designate investors who are nationals of certain countries as exempt from CFIUS review of real estate transactions near U.S. military installations. At this time, CFIUS has not provided a list of which countries will be exempt. In its September 27, 2019 informational conference call, the Treasury Department spokesman stated that there would be at least some countries on the list. While it would seem appropriate to exempt investors originating from certain close U.S. allies (e.g. Canada, United Kingdom, Australia, Japan), CFIUS’s recent exhaustive scrutiny of controlling investments in U.S. companies by investors from friendly countries raises significant doubts that more than two or three close U.S. allies will actually appear on any such “white list” included in the final rules.

Covered Transactions

Under the Proposed Regulations, CFIUS is authorized to review “covered real estate transactions” which include any purchase or lease by, or concession to, a foreign person – any foreign national, government or entity, or any entity controlled by a foreign national, government or entity – of covered real estate that affords the foreign person at least three of the following property rights:

  1. The right to physically access the real estate;
  2. The right to exclude others from physical access to the real estate;
  3. The right to improve or develop the real estate; or
  4. The right to attach fixed or immovable structures or objects to the real estate.

For example:

“Corporation A, a foreign person, acquires Corporation X, a U.S. business. As a result, Corporation X is a foreign person. Subsequently, Corporation X purchases [covered real estate] and obtains all of the property rights with respect to such real estate. Assuming no other relevant facts, the proposed transaction is a covered real estate transaction.” 84 Fed. Reg. 50229, Proposed Section 802.301(h) (Example 1).

“Corporation A, a U.S. business purchases covered real estate . . . . Corporation B, a foreign person, leases from Corporation A, a part of the real estate. Corporation B is entitled to at least three property rights with respect to the real estate as a result of the transaction. Assuming no other relevant facts, Corporation B’s lease is a covered real estate transaction.” Id. (Example 5).

Read literally, these definitions could sweep in a lease of farmland or in a marshy area for hunting purposes which include the right to put up a duck blind or a deer stand.

Lending Transactions

The Proposed Regulations do state that mortgages, loans, or similar financing arrangements by foreign persons for the purpose of the purchase, lease, or concession of covered real estate are not, by themselves, considered covered real estate transactions.

Rights of Foreign Foreclosure Could Trigger CFIUS Review. Foreign party financing arrangements may constitute covered real estate transactions where the terms of the arrangement give the foreign person property rights over the covered real estate, such as might occur in the event of foreclosure. It is unclear how the rules would treat the participation of a foreign bank in a syndicate or consortium of banks financing major real estate development. Uncertainties on this issue may chill the participation of legitimate foreign financing and inappropriately limit such financing sources, potentially raising financing costs.  

Declarations and Notices

There is no mandatory filing requirement for real estate transactions. But parties to transactions may file a notice or short form declaration notifying CFIUS of a covered real estate transaction in order to qualify for a “safe harbor” letter, preventing CFIUS from initiating a review of the transaction, subject to certain exceptions.   

CFIUS can contact parties to a pending transaction and require them to file. CFIUS can also demand that a transaction be undone if it determines after the fact that there are national security concerns. The ability to undo a closed transaction is a major incentive for submission of a voluntary notice.

Both the notice and the declaration require the parties to submit extensive information regarding the transaction and all parties involved. Items include, but are not limited to:

  1. the nature, value, financing sources and completion dates of the transaction;
  2. all relevant documents to the transaction;
  3. the property rights of all parties involved;
  4. a complete overview of the ownership structure of all parties involved, including the ultimate parent company, all intermediate parent companies and relevant ownership percentages; and
  5. a description of the business activities of the foreign persons involved.

This notice process has the potential to be extensive, costly, and at times intrusive into the business activities of all parties involved in a covered real estate transaction. Further, any material misstatements or omissions in the declaration or notice could result in a civil penalty of up to $250,000 per violation. CFIUS may either reject the declaration or notice, request additional information from the parties, or initiate a formal investigation of the transaction, which can take 30 to 45 days to complete. If experience with CFIUS reviews in the past year is any guide, the actual review time can be significantly longer, as CFIUS will sometimes suggest that parties withdraw and re-file in order to restart the review period and re-set the clock. Upon completion of an investigation, CFIUS can recommend to the President whether to suspend or prohibit the transaction. At least one foreign investment has been blocked in the past on the apparent ground that it gave a Chinese party the ability to observe U.S. Navy activities at a test range.

III.    The Comment Period Is Short

Treasury is accepting public comments to the Proposed Regulations until October 17, 2019. Final regulations are set to become effective no later than February 13, 2020.  Public comments will be critical to avoid significant overreach in these regulations, and potentially costly delays in closing real estate deals in locations near these military installations, ports, airports, and coastline areas.

Whether or not parties choose to comment, they should be preparing to address the possibility of such federal government reviews of major real estate transactions:

  • near the long list of military installations in Maryland, DC, and Virginia;
  • along the Atlantic coast of Maryland, Virginia, Delaware, and
  • rural real estate in much of Maryland and Virginia unless CFIUS clarifies the reach of Patuxent River Naval Air Station and Aberdeen Proving Ground review areas.

The complete text of the Proposed Regulations can be found on the Treasury website. It has also been published at 84 Fed. Reg. 50214 (Sept. 24, 2019). Please contact Russ Randle at Miles & Stockbridge if you would like further information about the Proposed Regulations.

Opinions and conclusions in this post are solely those of the author unless otherwise indicated. The information contained in this blog is general in nature and is not offered and cannot be considered as legal advice for any particular situation. The author has provided the links referenced above for information purposes only and by doing so, does not adopt or incorporate the contents. Any federal tax advice provided in this communication is not intended or written by the author to be used, and cannot be used by the recipient, for the purpose of avoiding penalties which may be imposed on the recipient by the IRS. Please contact the author if you would like to receive written advice in a format which complies with IRS rules and may be relied upon to avoid penalties.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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