KPMG report: Proposed regulations providing definition of domestically controlled real estate investment trust
Initial analysis and observations regarding proposed regulations under section 897
Initial analysis and observations regarding proposed regulations under section 897
The U.S. Treasury Department and IRS on December 28, 2022, released proposed regulations (REG-100442-22) providing rules for determining whether a real estate investment trust (REIT) is a domestically controlled REIT for purposes of section 897.
The proposed regulations [PDF 316 KB] also provide two new exceptions to the rule in the section 892 regulations that generally treats a U.S. real property holding corporation as a “controlled commercial entity” for purposes of section 892.
Read a January 2023 report [PDF 352 KB] prepared by KPMG LLP that provides initial analysis and observations regarding the proposed regulations.
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