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Jonathan Barros Vita

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IRS Issues Final Regulations for Foreign Investment in Qualified Investment Entities (REITS and RICS)

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By Devon Bodoh, Greg Featherman, Jonathan Barros Vita
| Lexology Verified
Overview On April 24, 2024, the Internal Revenue Service (“IRS”) and Treasury Department issued final regulations (T.D. 9992) under section 897 of the Internal Revenue Code of 1986, as amended (the “Code,” and such final regulations, the “Final Regulations”) detailing, among other things, whether a qualified investment entity (“QIE”) is domestically controlled for purposes of section 897(h)(2) of the Code (the “DC-QIE Exception”), and providing much needed clarification regarding the proper...
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