On December 28, 2022, the Internal Revenue Service and the Treasury Department released proposed regulations under sections 892 and 897 of the Internal Revenue Code.
On December 28, 2022, the Internal Revenue Service (the “IRS”) and the Treasury Department released proposed regulations (the “Proposed Regulations”) under sections 892 and 897 of the.
If finalized as proposed, the Proposed Regulations would prevent a non-U.S. person from investing through a wholly-owned U.S. corporation in order to cause a real estate investment trust REIT to be domestically controlled.