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Private Letter Ruling Exempts Subsidiary REITs From Preferential Dividend Rule

USA - June 18 2019 In a recent private letter ruling, the Internal Revenue Service concluded that a subsidiary REIT of a "publicly offered REIT" is exempt from the...

Anna Knecht Page, Joshua R. Venne, Kendal A. Sibley.

IRS Treats Subpart F Income Inclusions of Offshore TRSs as Qualifying Income for the REIT 95 Gross Income Test

USA - September 19 2018 New favorable guidance from the IRS (Revenue Procedure 2018-48, or the "Revenue Procedure") clarifies that subpart F inclusions of foreign taxable...

Kendal A. Sibley, Thomas R. Popplewell.

Final Section 385 Treasury Regulations Offer Good News for Most REITs

USA - October 20 2016 On October 13, 2016, the Internal Revenue Service ("IRS") and Treasury Department published final and temporary Treasury regulations (the "Final...

Allison M. Stelter, Kendal A. Sibley.

Proposed Treasury Regulations May Recharacterize TRS Debt

USA - April 20 2016 On April 4, 2016, the Internal Revenue Service ("IRS") and Treasury Department proposed new Treasury regulations (the "Proposed Regulations") that, if...

Allison M. Stelter, Kendal A. Sibley.

IRS revises distressed mortgage loan guidance for REITs

USA - August 29 2014 On August 22, 2014, the Internal Revenue Service ("IRS") issued Revenue Procedure 2014-51 (the "New Revenue Procedure"), which allows real estate...

Mark C. Van Deusen, Christopher Mangin.