Creating U.S. Tax Synergies between Qualified Foreign Pension Funds and REITs

Vasudha Anil Kumar and Max Levine of Linklaters New York’s Tax practice co-authored a Tax Notes article titled “Creating U.S. Tax Synergies between Qualified Foreign Pension Funds and REITs.” This article analyzes the qualification requirements for qualified foreign pension funds (QFPFs) and qualified controlled entities (QCEs), as well as the qualification and operation of real estate investment trusts (REITs) under U.S. federal income tax laws. It also examines the U.S. federal income tax structuring considerations for QFPFs and QCEs investing directly or indirectly in REITs.