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Proskauer - Tax Talks

Final Regulations on Domestically Controlled REITs

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On April 24, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations on the definition of “domestically controlled” real estate investment trusts (“REITs”)...more

Vinson & Elkins LLP

IRS Releases Favorable Guidance on the Tax Treatment of Payments to REITs and MLPs for Subsurface Carbon Dioxide Storage

Vinson & Elkins LLP on

Along with the broader market, real estate investment trusts (“REITs”) and publicly traded partnerships, frequently referred to as master limited partnerships (“MLPs”), have increasingly embraced the principles of...more

Holland & Knight LLP

Proposed Treasury Regulations Reverse Guidance on Domestically Controlled REITs

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more

King & Spalding

IRS and Treasury Issue Interim Guidance on 1% Stock Buyback Tax

King & Spalding on

On December 27, 2022, the IRS and Treasury issued Notice 2023-2 (the “Notice”), which provides guidance relating to the application of the new excise tax on repurchases of corporate stock (the “Stock Buyback Tax”) under...more

Dechert LLP

Final IRS Regulations for RICs to Passthrough REIT Dividends Eligible for 20% Deduction

Dechert LLP on

The U.S Department of the Treasury and the Internal Revenue Service on June 24, 2020 issued final tax regulations ("Final Regulations") that permit a regulated investment company (“RIC”) to report to its shareholders the...more

Morgan Lewis

COVID-19 Considerations for RICs and REITs and Temporary Relief on Certain Stock Distributions

Morgan Lewis on

New guidance from the Internal Revenue Service will allows RICs and REITs to retain more capital by distributing less cash to shareholders in certain stock distributions—welcome relief during the current economic volatility...more

Vinson & Elkins LLP

IRS Eases Cash/Stock Dividend Rules In Response To COVID Crisis

Vinson & Elkins LLP on

On May 4, 2020, the Internal Revenue Service (“IRS”) released Revenue Procedure 2020-19, which temporarily increases to 90% the percentage of stock certain real estate investment trusts (“REITs”) may issue in an elective...more

Proskauer - Tax Talks

Covid-19: Tax Considerations for REITs

Proskauer - Tax Talks on

This blog post summarizes some of the tax considerations for REITs that have arisen in light of COVID-19, the resulting economic downturn, the Coronavirus Aid, Relief, and Economic Securities (“CARES”) Act, and the Families...more

Latham & Watkins LLP

Final Section 956 Regulations Open the Door to Foreign Credit Support for US Corporate Borrowers

Latham & Watkins LLP on

Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax. On May 23, 2019, the US Treasury and Internal...more

Dechert LLP

Part Cash, Part Stock, 100% Taxable – New IRS Guidance on RIC and REIT Distributions

Dechert LLP on

The U.S. Internal Revenue Service (“IRS”), on August 11, 2017, issued Revenue Procedure 2017-45 (the “New Revenue Procedure”).1 Pursuant to the New Revenue Procedure, the IRS will treat part cash and part stock distributions...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Guidance on Stock/Cash Dividends for REITs and RICs

On August 11, 2017, the Internal Revenue Service released guidance allowing publicly offered real estate investment trusts and regulated investment companies to distribute earnings in a combination of cash and stock as long...more

Baker Donelson

What You Need to Know About Hospitality REITs

Baker Donelson on

In February 2016, Hilton Worldwide announced its plans to spin off the bulk of its hotel real estate into a publicly traded real estate investment trust (REIT) to be owned by its shareholders by the end of the year. The...more

Latham & Watkins LLP

IRS Adds Certain Spin Transactions to the “No Rule” List

Latham & Watkins LLP on

Treasury and IRS announce that certain “cash rich” and REIT/RIC conversion spin-offs are under study and are added to the “no rule” list. On September 14, 2015, the United States Treasury Department (the Treasury) and...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

McDermott Will & Emery

IRS Issues Another Significant Ruling on Spin-off of Real Estate

In certain recent transactions, a corporation distributes a subsidiary corporation holding the distributing corporation’s real estate assets to the distributing corporation’s shareholders in a tax-free “spin-off.” Not only...more

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