Featured Resources
Shiukay Hung, partner, co-chair, national REIT tax practice at DLA Piper, sat down for a video interview at Nareit’s REITwise: 2026 Educational Conference in Hollywood, Florida, March 24-26.
DLA Piper Tax Partner Shiukay Hung joins the AFIRE Podcast to unpack the implications of the newly signed 'One Big Beautiful Bill' - a tax reform with major relevance for cross-border property investors. Tune in for insights on international treaties, domestic exemptions, and the bond market’s role in shaping policy.
In this alert, we look at key components of the final regulations and what they mean for real estate funds, joint ventures, and investors.
Shiukay Hung,
Jesse A. Criz,
Allen P. Ashley et. al.
We answer some frequently asked questions about the changing REIT tax landscape.
Shiukay Hung,
Jesse A. Criz,
Allen P. Ashley et. al.
Please check out our quarterly REIT Tax newsletter for an overview of the latest REIT Tax News.
Shiukay Hung,
Jesse A. Criz,
Allen P. Ashley et. al.
Please check out our REIT Tax Client Alerts for thought leadership on REIT tax topics of interest.
Shiukay Hung, partner and co-chair of the national real estate tax practice at DLA Piper, participated in a video interview during Nareit’s REITwise: 2024 Law, Accounting & Finance Conference held March 19-21 in Hollywood, Fla.
Primary Materials
Legislative history
Internal Revenue Code
- Part II of Subchapter M (856)
- Part II of Subchapter M (857)
- Part II of Subchapter M (858)
- Part II of Subchapter M (859)
Treasury regulations
- 2025 Proposed Domestically Controlled REITs
- 2024 Final Domestically Controlled REITs
- 2024 Final REITs Transfer of Energy Credits Regulations
- 1.856-1; 1.856-2; 1.856-3; 1.856-4; 1.856-5; 1.856-6; 1.856-7; 1.856-8; 1.856-9; 1.856.10
- 2022 Proposed Domestically Controlled REITs
IRS notices
Tax forms
- Form 1120, REIT, US Income Tax Return for Real Estate Investment Trusts
- Form 8612, Return of Excise Tax on Undistributed Income of Real Estate Investment Trusts
- Form 8832, Entity Classification Election
- Form 8875, Taxable REIT Subsidiary Election
- Form W-8EXP, Certificate of Foreign Government or Other Foreign Organization – NEW
Private Letter Rulings (And Related DLA Piper Commentary)
Rents from Real Property / Qualifying Income- PLR 202601013 – Interest Rate Swaps Excluded from RETTI (REIT Tax News – March 2026)
- PLR 202530005 – EV Charging Qualifying Income (REIT Tax News – September 2025)
- PLR 202520010 – Cold Storage Services Income (REIT Tax News – June 2025)
- PLR 202510011 – Airport Terminal Space Income (REIT Tax News – March 2025)
- PLR 202413004 – EV Stations Not Impermissible (REIT Tax News – July 2024)
- PLR 202410005 – Oil And Gas Pipeline Fees (REIT Tax News – April 2024)
- PLR 202405001 – Government Bond Payment Income (IRS Rules Certain Income from Government Bonds Qualifies for REIT Income Tests)
- PLR 202346008 – Floating Docks Real Property (REIT Tax News – December 2023)
- PLR 202334007 – Carbon Dioxide Storage Income (IRS Rules Subsurface Carbon Dioxide Storage Payments Are Qualifying REIT Income)
- PLR 202304003 – Parking And Tenant Services (New REIT Tax Guidance on Parking, Amenity Space and Modern Tenant Services)
- PLR 202429003 – C-PACE As Qualified Mortgage (REIT Tax News – October 2024)
- PLR 202409002 – Brownfield Credits Qualifying Asset (REIT Tax News – April 2024)
- PLR 202402002 – Carbon Emission Offsets Income (REIT Tax News – November 2024)
- PLR 202401011 – Carbon Offset Credits Income (REIT Tax News – April 2024)
- PLR 202415001 – Retirement Community Not Healthcare Facility (REIT Tax News – July 2024)
- PLR 202317017 – Retirement Community Not Healthcare Facility (REIT Tax News – July 2023)
- PLR 202538013 – Consent Dividend In Liquidation (REIT Tax News – December 2025)
- PLR 202440007 – New REIT with No Initial Assets (IRS Approves New REIT with No Initial Income or Assets)
- PLR 202344007 – Inadvertent REIT Election Relief (REIT Tax News – December 2023)
- PLR 202340012 – TRS Late Election Relief (REIT Tax News – December 2023)
- PLR 202336001 – REIT Election Time Extension (REIT Tax News – October 2023)
- PLR 202334011 – TRS Election E-Signature Issue (REIT Tax News – October 2023)
- PLR 202314010 – TRS Election Miscommunication Relief (REIT Tax News – July 2023)
Awards and Recognitions
About DLA Piper’s National REIT Tax Practice
DLA Piper’s National REIT Tax practice has in-depth knowledge and experience advising US-listed public REITs, Singapore-listed public REITs, non-traded public NAV REITs, mortgage REITs, and private REITs on REIT taxation matters including formation, operation, acquisition, disposition, joint ventures, M&A transactions, restructurings, workouts and transactions under Chapter XI of the US Bankruptcy Code. Our attorneys are recognized as industry leaders by Chambers and Legal 500 and regularly publish articles in legal and trade publications and actively participate in real estate and REIT industry organizations.