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The legislative history behind FIRPTA and the 2003 amendment to the language of Code Sec. In particular, the legislative history of Code Sec. shareholder “would be treated as gain on the sale of U. real property to the extent of the shareholders’ pro rata share of the net capital gain of the REIT.” Such language is instructive, as “net capital gain” in the context of the REIT rules under the Code and Treasury Regulations is used in reference to capital gain dividends rather than liquidating distributions. 857(b)(3)(C), a REIT is permitted to designate as “capital gain dividends” its regular dividends, up to the amount of its “net capital gain” for the year.

person (including a foreign corporation) is generally subject to the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”). 897(h)(1) or being exempt from taxation under Code Sec. Such regulations, if issued, would apply to distributions occurring on or after June 13, 2007.

Under Notice 2007-55, discussed below, the IRS stated in part that it would challenge any assertion by a taxpayer that Code Sec. However, for the reasons set forth below, many tax professionals believe that Notice 2007-55 incorrectly interprets Code Sec.

person by a REIT (whether or not domestically controlled) attributable to a sale or exchange by the REIT of a USRPI will be treated as gain recognized by the non-U. person from the sale of a USRPI, which will be subject to FIRPTA tax.

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.

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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.