Recent Ruling Highlights Potential Pitfall in Corporate Reorganizations Involving Foreign Investors of U.S. Real Estate

The Journal of Real Estate Taxation, Volume 24, Number 2

Marc Gerson discusses Private Letter Ruling 9623028. Gerson notes that the ruling highlights the potential pitfalls in applying Section 897(e) in the context of a corporate reorganization involving foreign investors in U.S. real estate.

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