News & Analysis as of

Internal Revenue Code (IRC) Equity Real Estate Investment Trust

Morrison & Foerster LLP

Frequently Asked Questions about UPREITs and OP Unit Transactions

A common structure for equity REITs, the UPREIT model allows a REIT to hold and operate its assets through a single operating partnership. This structure provides tax advantages and liquidity opportunities for property...more

Troutman Pepper Locke

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

Troutman Pepper Locke on

Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

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