The document discusses the tax implications and obligations related to contributions of assets to a partnership in exchange for partnership interests, particularly in the context of a Real Estate Investment Trust (REIT). It covers the potential tax consequences of asset contributions, withholding obligations for non-U.S. partners, and the implications of failing to qualify as a REIT. The document outlines the conditions under which relief provisions may apply to avoid disqualification as a REIT and the tax consequences if such relief is not available.
doj/DataSet10/EFTA01384999.pdf
{"document_type":"legal","reference_numbers":["DB-SDNY-0085789","SDNY_GM_00231973","EFTA01384999"]}