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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...
If finalized as proposed, the Proposed Regulations would prevent a non-U.S. person from investing through a wholly-owned U.S. corporation in order to cause a real estate investment trust REIT to be domestically controlled.
Therefore, the excise tax is not limited to deeds or other instruments that will be recorded in the registry of deeds.
Mark Twain once said, “Buy land, they’re not making it anymore.” Perhaps it is this sentiment (along with returns on investments) that has led to the popularity of real estate...
IRS Private Letter Ruling 202226008, 07/01/2022: A foreign purchaser bought all the stock of a foreign target (controlled foreign corporation) which was a qualified stock purchase under...