New Proposed Regulations Would Affect The Taxation Of Foreign Investors In U.S. Real Estate
The Internal Revenue Service (“IRS”) released proposed regulations (REG-100442-22) (“Proposed Regulations”) that provide guidance on how indirect ownership is taken into account for purposes of determining whether a real estate investment trust (“REIT”) is “domestically controlled.” The Proposed Regulations also address the tax treatment of certain sovereign investing entities and modify the definition of “controlled commercial entity” under Section 892 of the Internal Revenue Code. The rules are particularly important for the real estate […]