REITs With International Operations Get Welcome IRS Ruling

On Sept. 13, 2018, the Internal Revenue Service published revenue procedure 2018-48 concerning the proper treatment of certain types of income from foreign operations for purposes of the real estate investment trust, or REIT, income tests after the enactment of the Trump Administration’s Tax Cuts and Jobs Act of December 2017. The revenue procedure provides important, and very welcome, albeit limited, relief to REITs with international operations on certain unanswered questions, both existing under old law, as well as created by the TCJA.