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331 for the difference between the FMV and the shareholder’s basis in the stock).

As a result, the tax consequences of a subsequent sale of the assets by the shareholder should be minimal. The corporation is treated as selling the distributed assets for FMV to its shareholders, with the resulting corporate-level tax consequences.

The Senate Report explained that the 5% Exception was meant to remove “from treatment as effectively connected income for a foreign investor a capital gain distribution from a REIT” and justified it as a means to “provide greater conformity in the tax consequences of REIT distributions and other corporate stock distributions.” The use of the language “capital gain distribution from a REIT” would suggest that the Senate Report was referring to capital gains dividends, rather than liquidating distributions and that the distributions to which the 5% Exception (and, thus, Code Sec. 857(b)(3)(F), enacted at the same time as the 5% Exception, which recasts distributions subject to the 5% Exception as ordinary dividends, applies only to the amount which would be considered capital gain dividends (and not liquidating distributions). 897(h)(1) is applied in accordance with the Notice, a non-U. shareholder to which the 5% Exception applied on a liquidating distribution would not be subject to FIRPTA tax nor would the distribution be subject to withholding as an ordinary dividend under Code Sec. This disparity in treatment would suggest again that Congress did not intend Code Sec. To not treat liquidating distributions as ordinary dividend income subject to Code Sec. Such inconsistencies would not exist if liquidating distributions from a DCR were treated consistently with the provisions of Subchapter C of the Code.

897(h)(1)) applied were not liquidating distributions. 897(h)(1) also fosters the goal of greater conformity in the tax consequences of REIT distributions and other corporate stock dividends stated under the Senate Report. shareholder could be subject to branch profits tax on liquidating distributions. Although liquidating distributions to domestic shareholders are generally treated as a sale of stock and are exempt from FIRPTA taxation, as discussed above, the same distributions to non-U.

person is generally not subject to FIRPTA (or other U. The stated purpose of Notice 2007-55 was to discuss what the IRS viewed as the inappropriate treatment by foreign governments of certain distributions from DCRs to such foreign governments as not being subject to tax under Code Sec. 897(h)(1) includes a liquidating distribution from a DCR attributable to gain from the sale or exchange of a USRPI.

897(h)(1) should not apply to liquidating distributions from DCRs to non-U. 897(h)(1), and that such section only applies to non-liquidating distributions, and not to liquidating distributions. 897(h)(1) did not apply to distributions in complete liquidation of a DCR to such non-U. taxpayer and (ii) issue regulations to clarify that the term “distribution” under Code Sec.

Therefore, the use of “net capital gain” in the Congressional Report would suggest that Congress did not intend for Code Sec. The accompanying 2003 Senate Report to the amendment to Code Sec. 897(h)(1) was not intended to apply to liquidating distributions from DCRs. 897(h)(1), a distribution by a qualified investment entity with respect to any publicly traded class of stock is not treated as gain recognized from the sale or exchange of a USRPI if the non-U. shareholder owned 5% or less of such class of stock during the one-year period ending on the date of such distribution (the “5% Exception”).

897(h)(1) suggests an intent to treat liquidating distributions from DCRs as exempt from U. 897(h)(1) suggests that Congress viewed capital gain dividends, rather than liquidating distributions, as the tax base for Code Sec. The Congressional Report accompanying the original FIRPTA legislation states that, under Code Sec. The rule does not, however, permit any liquidating distributions to be treated as “capital gain dividends.” This complies with the general treatment of liquidating distributions under Subchapter C of the Code as an amount paid by a liquidating corporation to its shareholders in exchange for their stock rather than a dividend.

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The shareholders generally recognize gain (or loss) in an amount equal to the difference between the fair market value (FMV) of the assets received (whether they are cash, other property, or both) and the adjusted basis of the stock surrendered.

“When we first launched Hines REIT in 2003, it was structured as a perpetual life vehicle, much like many institutional funds,” said Sherri Schugart, president and CEO of Hines REIT.

“Impacts from the great recession caused us to close the fund to new investors in 2009, so we began considering other options that could provide the best opportunities for enhancing stockholder value through the following economic recovery.

In light of the pending plan, the Company will cease paying regular quarterly distributions after payment of distributions declared for the second quarter of 2016 and instead expects to make final distributions to its stockholders on or before December 31, 2016.

There can be no assurances regarding the amounts of any distributions or the timing thereof.