United States: Revenue Ruling 2008-31: IRS Rules That A Swap Interest In A...
Mondaq: 1 views since Thursday, July 3, 2008 at 04:32 AM
On June 12, 2008, the Internal Revenue Service ("IRS") published Revenue Ruling 2008-31, I.R.B. 2008-26 (the "Ruling"), holding that an interest in a notional principal contract that references data from an index derived from a geographically and numerically broad range of U.S. real estate values does not constitute a United States real property interest ("USRPI") for purposes of the Foreign ...

Published in: Real Estate & Property