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Revenue Ruling 2008-31: IRS Rules That a Swap Interest in a Broad-Based U.S. Real Estate Index Is Not a U.S. Real Property Interest under FIRPTA


by Thomas A. Humphreys View Biography
Morrison & Foerster LLP View Firm Credentials
New York Office

Donald Lee
Morrison & Foerster LLP View Firm Credentials
San Francisco Office

July 11, 2008

Previously published on June 2008

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....


 

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