Mergers and acquisitions in an UPREIT/downREIT world

Article Abstract:

Real estate investment trust (REIT) mergers and acquisitions, an increasingly important aspect of the expanded REIT industry, raise a number of tax issues by their very structure. UPREITs, or umbrella partnership REITs, are the major innovation in the industry, but mergers involving these structures are complicated transactions, involving remote continuity issues and similar problem areas. The ROC/Chateau, McArthur/Glen, and Simon/DeBartolo transactions are examples of REIT-UPREIT mergers.

Mergers & Acquisitions, Real estate investment trusts, Real Estate Invest Trusts

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Qualified nonrecourse financing regulations offer guidance but leave unanswered questions

Article Abstract:

IRS final regulations regarding qualified nonrecourse financing and the exception for the at-risk rules were issued Aug 1998 and provide clarification and positive treatment of certain issues. IRC deduction limitation section 465 mandates carryforwards of losses which may be deductible if the at-risk rules continue to be met. The regulations provide clarification of issues specific to limited liability companies, but some issues remain open.

Public Finance Activities, Tax Deductions & Exemptions, Laws, regulations and rules, Limited liability companies, Tax deductions, Nonrecourse debt

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Proposed regulations concerning partnership mergers and divisions provide guidance and some, but not enough, flexibility

Article Abstract:

The author examines IRS regulations proposed under IRC section 708 regarding partnership taxation following mergers or divisions.

United States, Acquisitions and mergers

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