IRS Issues Final Regulations on U.S. Real Property Interests Held by Foreign Pension Funds
Published December 28, 2022
The Internal Revenue Service (IRS) issued final regulations regarding the exception from taxation with respect to gain or loss of a qualified foreign pension fund attributable to certain interests in United States real property.
The final regulations:
- Include rules for certifying that a qualified foreign pension fund is not subject to withholding on certain dispositions of, and distributions with respect to, certain interests in United States real property; and
- Affect certain holders of interests in United States real property and withholding agents that are required to withhold tax on dispositions of, and distributions with respect to, such property.
The regulations are effective on December 29, 2022.