News & Analysis as of

Corporate Taxes Real Estate Investment Trust Spinoffs

A&O Shearman

IRS Expands Scope of Spin-Off Private Letter Rulings in 18-Month Pilot Program

A&O Shearman on

On September 21, 2017, the IRS announced in Revenue Procedure 2017-52 (the “Pilot Program Rev. Proc.”) that it is expanding the scope of spin-off private letter ruling requests that it will consider. The pilot program is...more

Morrison & Foerster LLP

Treasury Expands Scope of REIT Spin-Off Rules in New Regulations

On June 7, the Treasury Department released temporary regulations (the “Temporary Regulations”) that expand the types of spinoff transactions subject to the rules under Section 337(d)2 requiring gain recognition where either...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Extenders Bill Makes Important REIT Reforms and Closes Door on REIT Spinoffs"

President Obama signed into law a bill that will significantly reform the taxation of real estate investment trusts (REITs). Most notably, the Protecting Americans from Tax Hikes Act of 2015 (the Bill) prevents companies from...more

Goulston & Storrs PC

IRS Suspends Private Rulings on Many REIT Spin Off Conversions

Goulston & Storrs PC on

The flurry of Opco-Propco REIT conversions has hit a stumbling block this week when the IRS issued a Revenue Procedure announcing a “no rule” policy for a key corporate tax issue for many REIT spin offs. Basically to do a...more

Morrison & Foerster LLP

New IRS Guidance Limits Tax-Free Spin-Off Rulings – Implications for REIT Spin-Offs

On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more

Cadwalader, Wickersham & Taft LLP

M&A Update: Market Pressures, Favorable Law Spur REIT Conversions and Spinoffs

Urged on by activists and institutional shareholders, a large number of companies with real estate holdings pursued real estate investment trust (REIT) conversions or spinoffs in 2014. At least half a dozen companies...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - November 2014

McDermott Will & Emery on

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

Davis Wright Tremaine LLP

Are REITs a Viable Strategy for Communications Companies?

Windstream Holdings, Inc. recently announced plans to spin off its copper, fiber and other fixed real estate assets into an independent publicly traded real estate investment trust (REIT). Windstream received a private letter...more

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