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Tax Liability Real Estate Investment Trust Tax Planning

Vinson & Elkins LLP

Update: OBBBA Tax Provisions Impacting REITs and Foreign Investors

Vinson & Elkins LLP on

On July 1, 2025, a little over two weeks after the Senate Finance Committee released its draft tax title (the “Initial Senate Draft”), the U.S. Senate secured sufficient votes to advance its version of the “One Big Beautiful...more

Vinson & Elkins LLP

Senate Draft Tax Provisions Impacting REITs and Foreign Investors

Vinson & Elkins LLP on

On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”). While the Senate...more

Sullivan & Worcester

Sullivan & Worcester Submits Comments to IRS Urging Caution in Applying Cloud Transaction Framework to REIT Rules

Sullivan & Worcester on

On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more

Sullivan & Worcester

Remediation of M&A REIT Targets (UPDATED)

Sullivan & Worcester on

The past is prologue: Do REIT qualification issues close with tax years, do they persist for ten (10) years (being the sum of five (5) years on account of the Section 856(g)(3) “lock out” plus another five (5) years of...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

Proskauer - Tax Talks on

On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Cadwalader, Wickersham & Taft LLP

Revenue Adjusted Lease Payments Are Not REIT Qualifying Income

On February 4, 2022, the IRS released a private letter ruling revoking its prior approval of certain lease payments as “rents from real property” for purposes of the REIT income tests....more

Freeman Law

What is a REIT? Real Estate Investment Trusts and Taxation

Freeman Law on

REITs, or real estate investment trusts, are often described as a mutual fund for real estate.  Congress established REITs to allow individual investors to invest in large-scale, income-producing real estate. Since their...more

Cadwalader, Wickersham & Taft LLP

Closing the Books November 2021 - The UK's Autumn Budget 2021: Implications for Real Estate

As we draw close to the end of the year, we take a moment to revisit some of the taxation changes announced in the Autumn budget, with some of these being implemented in the upcoming tax year in April 2022. ...more

Stinson LLP

IRS Releases Carried Interest Proposed Regulations

Stinson LLP on

On July 31, the IRS issued proposed regulations under Section 1061 of the Internal Revenue Code further clarifying the tax treatment of carried interest and other "applicable partnership interests" (APIs)....more

Skadden, Arps, Slate, Meagher & Flom LLP

Oil Price War and Challenging Debt Markets: Tax Risks and Strategies for Upstream and Midstream Companies

Many upstream and midstream companies are grappling with the prospect of severe liquidity constraints due to the rapid deterioration of both the commodity markets and the debt capital markets. While upstream companies have...more

McDermott Will & Schulte

Weekly IRS Roundup June 3 – 7, 2019

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

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