News & Analysis as of October 13, 2024

U.S. Treasury

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Final ‘Domestically Controlled REIT’ Regulations Retain Corporate Look-Through With Some Modifications

Skadden, Arps, Slate, Meagher & Flom LLP on 4/30/2024

On April 24, 2024, the Treasury Department released final regulations that alter key rules affecting many real estate funds and foreign investors in U.S. real estate....more

Proposed Regulations Would Impact Taxation of Investment in U.S. Real Estate by Non-U.S. Investors

King & Spalding on 1/20/2023

On December 29, 2022, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) addressing (1) whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute...more

New Proposed Regulations Would Impact the Determination of Domestically Controlled REIT and Structures for Sovereign Wealth Funds’...

Proskauer - Tax Talks on 1/16/2023

On December 28, 2022, the Internal Revenue Service (the “IRS”) and the Treasury Department released proposed regulations (the “Proposed Regulations”) under sections 892 and 897 of the Internal Revenue Code (the “Code”). If...more

Department of Treasury Releases Proposed Regulations Offering Pandemic Relief to Qualified Opportunity Zone Businesses

Burr & Forman on 4/27/2021

On April 14, 2021, the Department of Treasury (“Treasury”) released proposed regulations (the “Proposed Regulations”) that, if adopted, would allow flexibility for qualified opportunity zone businesses (“QOZBs”) to revise or...more

Proposed Regulations Provide Clarity for Qualified Foreign Pension Fund Exception

Proskauer - Tax Talks on 7/5/2019

On June 7, 2019, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed Treasury regulations under Sections 897, 1445 and 1446 (the “Proposed Regulations”) regarding the exception...more

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