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Real Estate Investment Trust Foreign Investment Pension Funds

Davies Ward Phillips & Vineberg LLP

IRS Relaxes Rules for Domestically Controlled REITs

Non-U.S. investors are generally subject to U.S. federal income tax on gains from investments in private U.S. real estate investment trusts (REITs). Two exceptions (among others) are for investments in “domestically...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2022 and a Look Ahead to 2023

As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us. Review of U.S. Tax Developments in 2022- In 2022 we...more

Morgan Lewis

IRS Issues Proposed Regulations Applicable to Qualified Foreign Pension Funds and Sovereign Wealth Funds

Morgan Lewis on

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

Troutman Pepper

Reforms to the Foreign Investment in Real Property Tax Act and REIT Taxation - Tax Update Volume 2016, Issue 1

Troutman Pepper on

The reforms generally encourage foreign investment in U.S. real estate. The enacted Protecting Americans from Tax Hikes Act of 2015 (the Act) contains numerous reforms to the Foreign Investment in Real Property Tax Act...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Key Takeaways: Changes Will Impact Investment in US Real Estate"

On May 4, 2016, Skadden presented the seminar “How FIRPTA and REIT Changes Will Impact Investment in US Real Estate.” Congressman Joseph Crowley, D-N.Y., gave the introductory remarks, and panelists included Jeffrey DeBoer,...more

Proskauer - Tax Talks

Real Estate Investments by Qualified Foreign Pension Funds After the PATH Act

Proskauer - Tax Talks on

The Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) included a number of significant changes to the U.S. federal income tax rules related to real estate investment trusts (“REITs”) and investments by non-U.S....more

Dechert LLP

PATH Act Creates New FIRPTA Withholding Tax Rate and Exemption for Foreign Pension Funds

Dechert LLP on

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed into law on December 18, 2015, has resulted in a number of changes to the taxation of investments in U.S. real property by foreign investors. Among...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Important FIRPTA and REIT Reforms Enacted"

The newly signed Protecting Americans from Tax Hikes Act of 2015 (the Act) includes several reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) and the taxation of real estate investment trusts...more

Morgan Lewis

New PATH Act Changes Rules for Foreign Investment in US Real Estate and for REITs

Morgan Lewis on

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

King & Spalding

PATH Act Provides Favorable New Rules for Foreign Real Estate Investment Through REITs

King & Spalding on

On Friday, December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). The PATH Act includes a number of important changes relating to the tax treatment of foreign...more

Skadden, Arps, Slate, Meagher & Flom LLP

"New FIRPTA Reform: The Long-Awaited Game Changer for US Real Estate"

On December 18, 2015, President Obama signed into law a bill that will significantly reform the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). The Protecting Americans from Tax Hikes Act of 2015 (the Bill) will...more

Goodwin

Commerce Department Survey of Financial Services Transactions with Foreign Persons Due November 1, 2015

Goodwin on

The Commerce Department’s BE-180 Survey of Financial Services Transactions is a mandatory benchmark survey conducted every five years and administered by the Bureau of Economic Analysis (the “BEA”). Reports are required by...more

Skadden, Arps, Slate, Meagher & Flom LLP

"FIRPTA Reform Opens Door to Increased Foreign Investment in US Real Estate"

This afternoon, Reps. Kevin Brady (R-Texas) and Joseph Crowley (D-N.Y.) re-introduced in the House of Representatives a bill to significantly reform the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R....more

Skadden, Arps, Slate, Meagher & Flom LLP

"Senate Finance Committee Takes Unanimous Step Toward FIRPTA Reform"

On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more

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