author_orbitax
Orbitax

Share This Article

US UPREIT is a capture foreign collective investment vehicle

25 March 2013

|

Approved Changes

|

Australia; United States

On 11 January 2013, the Australian Taxation Office released Interpretative Decision ATO ID 2013/3 in which it confirmed that in an arrangement where a US Limited Partnership effective operates as one within an UPREIT arrangement with US Real Estate Investment Trust (REIT) and manages the day-to-day operations of the US REIT, the investment of the US REIT will qualify as a capture collective investment vehicle. This, in turn, will allow, other things being equal, an Australian trust, in which the US REIT is an investment, to qualify as a Managed Investment Trust and to access a number of income tax...