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Date

Tags:

Rule
7A(c)(1)
Staff
Nora Whitehead
Response/Comments

The REIT Exemption, 7A(c)(1), does not extend to foreign REITs.

Question

From: Whitehead, Nora
Sent: Friday, October 16, 2015 1:46 PM
To: [REDACTED]
Cc: Walsh, Kathryn E.; Gillis, Diana L.
Subject: RE: REIT Exemption

 As of right now, we are not prepared to extend the REIT exemptions to foreign REITs.

 Nora Whitehead

(202) 326-3262

Check out the PNO Blog!

 

From: [REDACTED]
Sent: Friday, October 16, 2015 1:28 PM
To: Walsh, Kathryn E.; Berg, Karen E.; Gillis, Diana L.; Whitehead, Nora
Subject: REIT Exemption

 

Hi all – Would the PNO treat non-US REITs the same as US REITS for the purposes of the “REIT Exemption”?  The foreign REIT would be in the business of buying, owning, leasing and selling real property.   I couldn’t find any guidance online.    

 

Many thanks,

[REDACTED]
 

About Informal Interpretations

Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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