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REITs — A Two Pipe Problem

John Watson of Ashurst offers some suggestions for suitable structures for REITs

 
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...

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