Real Estate Tax Alert: Summary of REIT private letter rulings

June 2012

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At a glance

In Rev. Rul. 2012-17, the Internal Revenue Service has ruled that a REIT’s investment in the shares of a money market fund constitutes an investment in "cash and cash items" for purposes of section 856(c)(4)(A) of the Internal Revenue Code.

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This alert summarizes certain significant private letter rulings issued by the IRS to REITs during the last year.

Download the latest NewsAlert to learn more.

Previous Newsalerts

2012

• The impact of FATCA withholding on real estate funds, real estate companies and real estate joint ventures (Part 2) - September 2012 - September 2012
• In Rev. Rul. 2012-17, the Internal Revenue Service (“IRS”) has ruled that a REIT’s investment in the shares of a money market fund constitutes an investment in “cash and cash items” for purposes of section 856(c)(4)(A) of the Internal Revenue Code (“Code”) - April 2012
• The impact of FATCA withholding on real estate funds, real estate companies and real estate joint ventures (Part 1) - April 2012 - April 2012
• IRS Publishes Form 8937 and Notice 2012-11 - January 2012

2011

• The Impact of FATCA on the Real Estate Industry - September 2011
• FIRPTA Withholding and Coordination of Withholding Rules under Internal Revenue Code Sections 1445 & 1446 - July 2011
• IRS Provides Guidance on Subpart F and PFIC Inclusions for the 95% REIT Test - June 2011
• Section 6045B Follow up - March 2011
• Allocation Issues for Open-End Real Estate Funds - February 2011
• IRS Provides Safe Harbors for Distressed Real Estate Backed Debt Under the 75 Percent REIT Income and Asset Tests - January 2011
• New York legislative Changes Impact on REIT clients - January 2011
• Section 6045B - January 2011

2010

• Expiring Soon: Grants for Specified Energy Property In Lieu of Tax Credits under the American Recovery and Reinvestment Act of 2009 - December 2010
• Deductibility of losses from the abandonment or worthlessness of partnership interests - November 2010
• The Hidden Price of a Civilized Society (FATCA and Leveraged C Corporations) - August 2010
• Foreign investment in US real property - July 2010
• The carried interest proposal and Massachusetts legislative changes - June 2010
• Foreign currency debt modifications - May 2010