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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 PNO staff on the applicability of the HSR rules to specific fact situations. They do not necessarily reflect the position of the Commission. 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. 

Learn more about Informal Interpretations.

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