News & Analysis as of

Tax Exemptions Real Estate Investment Trust

Proskauer Rose LLP

Proskauer’s Hedge Start: Key Tax Issues

Proskauer Rose LLP on

Different hedge fund investors have different tax concerns that must be taken into account when structuring a hedge fund and its portfolio investments. Hedge fund investors generally fall into three categories:...more

Husch Blackwell LLP

Texas Franchise Tax Updates for 2024

Husch Blackwell LLP on

The calendar year 2024 will bring multiple changes to the Texas franchise tax. Taxpayers responsible for entities operating in Texas should be aware of these rules as they plan for their filing and payment obligations in the...more

Morrison & Foerster LLP

On the REIT Track

UK real estate investment trusts (UK REITs) benefit from certain tax exemptions that have the effect of putting their shareholders in a tax position broadly equivalent to that of a direct investor in UK real estate. Those...more

Paul Hastings LLP

New Treasury Guidance on Sovereign Wealth Funds, Qualified Foreign Pension Funds, and REITS and RICs

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On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more

McDermott Will & Emery

Weekly IRS Roundup June 3 – 7, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019. June 4, 2019: The IRS issued a news release noting that it granted tax relief...more

Morrison & Foerster LLP

Trade tax exemption for real estate income in real estate managed indirectly through partnerships (German Version)

The BFH's Grand Senate also confirms the fundamental applicability of the trade tax exemption (so-called extended reduction) for real estate income generated by real estate management, non-commercial partnerships - The...more

Eversheds Sutherland (US) LLP

Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of...

On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...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

IRS Announcements Create Market Uncertainty for REIT Spin-Offs

Goodwin on

In issuing IRS Notice 2015-59 and Rev. Proc. 2015-43 last week, the IRS intentionally created significant market uncertainty about the viability of “PropCo/OpCo” spin-offs as part of the PropCo’s REIT conversion (e.g., where...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

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