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Searching Content indexed under Fund Management/ REITs by Grant Thornton LLP ordered by Published Date Descending.
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IRS Publishes Guidance On Stock Distributions For Publicly Offered REITs And RICs
On Aug. 11, the IRS published a revenue procedure (Rev. Proc. 2017-45) providing a set of procedures that a publicly offered REIT or a publicly offered RIC can follow to ensure that certain distributions...
United States
5 Sep 2017
2
IRS Rules Interest Is Qualifying REIT Income
The IRS Office of Chief Counsel ruled in a private letter ruling (PLR 201732012) released Aug. 11 that interest received by a REIT was qualifying income for purposes of the REIT income test under Section 856(c)(3).
United States
5 Sep 2017
3
IRS Issues Final Regs On Money Market Funds
The IRS has issued final regulations under Section 446 (T.D. 9774) that provide a simplified method of accounting for gains and losses on shares in a money market fund (MMF).
United States
22 Jul 2016
4
New Spin-Off Issues Under Study, IRS Says
In Notice 2015-59, the IRS announced there are several areas that are currently under study based upon characteristics of certain Section 355 spin-offs that concern the IRS due to possible abuse.
United States
15 Oct 2015
5
Senate Tax Writers Seek To Cut Alternative Fuel Taxes And Ease FIRPTA Burdens On REITs
The Senate Finance Committee approved a package of 17 relatively noncontroversial bills last week that includes provisions to ease restrictions under the Foreign Investment Real Property Tax Act of 1980...
United States
5 Mar 2015
6
IRS Rules On Bad Debt Deduction
In a private letter ruling http://www.irs.gov/pub/irs-wd/201450011.pdf (PLR 201450011), released on Dec. 12, the IRS said that a corporation could take a bad debt deduction under Section 166 related to payments made to a disputed ownership fund under Treas. Reg. Sec. 1.468B-9.
United States
6 Jan 2015
7
Is Your Bank On Track To Meet Volcker Conformance Standards?
The banking industry under the Volcker Rule has proven to be inherently complex. Recently, the conformance period has been extended to July 21, 2015
United States
 
27 Oct 2014
8
IRS Approves Section 355 Spinoff Of A REIT Formed By A Partnership
In private letter ruling 201436033, the IRS considered a transaction that involved the back-to-back distributions of a real estate investment trust.
United States
26 Sep 2014
9
IRS Provides Guidance For REITs Holding Distressed Mortgages
The IRS issued Rev. Proc. 2014-51, which supersedes Rev. Proc. 2011-16, concerning the treatment of safe harbors for purposes of determining real estate investment trust qualifications.
United States
26 Sep 2014
10
IRS Issues Guidance Package Related To Money Market Funds
The IRS on July 23 issued proposed regulations under Section 446 providing a simplified method of accounting for gains and losses on shares in a money market fund.
United States
27 Aug 2014
11
IRS Rules On REIT Asset And Income Tests
The IRS ruled that a real estate investment trustís right to receive a state franchise tax refund constitutes a receivable arising in the REITís ordinary course of operations.
United States
1 Aug 2014
12
Patronage Dividends Excludable From REITís Gross Income For Purposes Of Sections 856(c)(2) And (c)(3), IRS Says
The IRS ruled that a real estate investment trust could exclude certain patronage dividends from gross income for purposes of Sections 856(c)(2) and (c)(3).
United States
2 Jun 2014
13
Multiple Classes Of Common Stock Do Not Cause Preferential Dividends For A REIT, IRS Rules
The IRS ruled that having more than one class of common stock with different fee structures did not cause preferential dividends by a REIT.
United States
19 Mar 2014
14
IRS Rules That Parking Revenue Received By REIT, From REIT Subsidiaries, Is Rent From Real Property
In a private letter ruling (PLR 201341015), the IRS ruled that parking revenue received by a real estate investment trust (REIT) from certain parking facilities under parking management agreements with various taxable REIT subsidiaries qualified as rents from real property for purposes of Section 856(d).
United States
19 Dec 2013
15
IRS Approves REIT Election After Section 355 Spinoff
In a private letter ruling, the IRS approved the tax-free spinoff under Section 355 of real estate assets into a newly formed real estate investment trust.
United States
8 Oct 2013
16
IRS Rules That Corporation Is Not A Successor Corporation For Purposes Of Filing A Consolidated Tax Return
In Private Letter Ruling (PLR) 201214020, the IRS ruled that under Section 1504(a)(3), a spun-off corporation (Controlled) was not a "successor" to a distributing corporation (Distributing).
United States
17 Sep 2012
17
Excess Servicing Spread Is Ruled An Interest In Mortgages For REITs
The IRS ruled on May 24, 2012 (PLR 201234006), that an excess servicing spread acquired by a real estate investment trust (REIT) as defined in Section 856 was an interest in mortgages on real property and that the related interest income will qualify for purposes of determining whether the REIT satisfied the gross income tests of sections 856(c)(2) and 856(c)(3).
United States
13 Sep 2012
18
IRS Rules That Interest In Money Market Fund Is Cash Item For REIT Asset Test
The IRS has ruled (Rev. Rul. 2012-17) that an investment by a real estate investment trust (REIT) in a money market fund is an investment in "cash or cash items" for purposes of the REIT asset test.
United States
13 Jul 2012
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