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Taxation of Liquidating REIT Distributions to be Challenged by the IRS

September 4, 2007

Association of Foreign Investors in Real Estate, AFIRE News, July / August 2007

The US Internal Revenue Service (the “IRS”) issued a notice on June 13, 2007, indicating that it intended to challenge the position taken by some foreign investors in real estate investment trusts (“REITs”) that a liquidating sale and distribution by a REIT is not subject to taxation under the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”). In Notice 2007-55, I.R.B. 2007-27, the IRS stated that it not only would oppose under current statutory and regulatory provisions an assertion by any foreign taxpayer that the provisions of FIRPTA do not apply to distributions in complete liquidation of REITs or other qualified investment entities, but that it would also issue regulations to that effect applicable for distributions taking place after June 13, 2007.

Resources

AFIRE Newsletter July-August Hood.pdf

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