John Watson of Ashurst offers some suggestions for suitable structures for REITs
The key to finding a suitable structure for REITs is reconciliation. Not reconciliation in the political sense of course with junketing handshakes and plenty of drink but the reconciliation of a number of different requirements into a single structural framework. So let us start by looking at the treatment of income and try to reconcile the requirements there with a preference for the use of a corporate structure. So:
● the Treasury does not wish to lose tax that is the income from the underlying property must bear as much tax on its way to the investors as it would if those investors owned the property direct;
● on the other...
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John Watson of Ashurst offers some suggestions for suitable structures for REITs
The key to finding a suitable structure for REITs is reconciliation. Not reconciliation in the political sense of course with junketing handshakes and plenty of drink but the reconciliation of a number of different requirements into a single structural framework. So let us start by looking at the treatment of income and try to reconcile the requirements there with a preference for the use of a corporate structure. So:
● the Treasury does not wish to lose tax that is the income from the underlying property must bear as much tax on its way to the investors as it would if those investors owned the property direct;
● on the other...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
