The Treasury Department and the IRS said they would scrap a key aspect of their existing approach on whether US real estate investment trusts and other “qualified investment entities” are considered to be domestically controlled.
Treasury and the IRS proposed regulations Monday (REG-109742-25; RIN 1545-BR60) that would remove a “look-through” approach they imposed in 2024. That approach looks to the shareholders of domestic corporations in determining whether foreign persons hold stock directly or indirectly in a qualified investment entity.
Domestic control of qualified investment entities has tax implications for gains and losses from the disposition of US real ...