Tax Guidance on FIRPTA Exemptions for Foreign Pension Fund Real Estate Investments and REITs

Tax Guidance on FIRPTA Exemptions for Foreign Pension Fund Real Estate Investments and REITs The passage outlines legislative changes to FIRPTA tax treatment for foreign pension fund investments and REIT ownership thresholds. It provides technical details but no specific actors, transactions, or misconduct, limiting investigative value. The information is largely public policy and lacks novel scandalous implications. Key insights: New law exempts foreign pension fund capital gains from FIRPTA on raw land, mortgage loans, and U.S. blocker corporation stock sales.; Equity kicker mortgage loans are treated as U.S. real property interests under FIRPTA, but gains are now exempt.; Foreign investors can now own up to 10% of publicly traded REIT stock without triggering FIRPTA, up from 5%.