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Home 9 Publication 9 Tax-Attribute Carryforwards of Inactive US Real Estate: Holding Companies — A Valuable and Often-Overlooked Asset

Tax-Attribute Carryforwards of Inactive US Real Estate: Holding Companies — A Valuable and Often-Overlooked Asset

February 7, 2006

Association of Foreign Investors in Real Estate, AFIRE News, January/February 2006

Many foreign investors in US real estate have found themselves owning US or foreign companies with substantial US tax-attribute carryforwards resulting from investments that have been disposed of by the companies. The carryforwards may have arisen from economic loses, deductions generated by interest on related-party debt or both. The carryforwards may be isolated in a company that no longer owns any real estate even though the foreign investor continues to hold real estate through other companies. On the other hand, the carryforwards may be attached to companies that are owned by overseas concerns that have totally ceased their US real estate investment program. The question in all cases is how to obtain the maximum value from the carryforwards.

Resources

Tax Attribute Hood Feb 2006.pdf

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