New regs tackle property transfers from C corps to REITs and RICs

Description

Abstract: Last fall, the IRS issued long-awaited final regulations providing guidance on the recognition of built-in gains when the appreciated property of a C corporation becomes the property of a real estate investment trust (REIT) or regulated investment company (RIC). Such a situation can arise when a C corp becomes a REIT or RIC or because it transfers its property to a REIT or RIC in a “conversion transaction.” The regs include two important exceptions to the general rule on gain recognition. This article discusses that rule and the exceptions, while a sidebar looks at one exception that was rejected.