351(e) precludes the nonrecognition if the transferor transfers property to an investment company
, regardless of whether the company is an existing investment company
or a new one.
351-1(c)(1), a transfer of property after June 30, 1967, was considered to be a transfer to an investment company
if W the transfer results, directly or indirectly, in diversification of the transferors' interests, and (ii) the transferee is (a) a regulated investment company
(RIC), (b) a real estate investment trust (REIT), or (c) a corporation more than 80 percent of the value of whose assets (excluding cash and non-convertible debt obligations from consideration) are held for investment and are readily marketable stocks or securities, or interests in RICs or REITs.
Sovereign Investment Company
is one of the largest and fastest growing private equity investors providing sale/leaseback capital to owners, operators and developers of single-tenant, net-leased real estate.
This SOP applies to investment partnerships that are exempt from SEC registration under the Investment Company
Act of 1940 and defined as investment companies in paragraph 1.
Instead, the investment company
exception contained in the regulations applies to the first rule (ownership) and not the second rule (character as trade or business asset).
An investment company
qualifying under the Internal Revenue Code generally can avoid incurring federal income tax liabilities by distributing all its annual taxable income to shareholders.
The SEC order includes specific terms and conditions under which an investment company
may invest in an ETF in excess of the Investment Company
Fully owned by the Qatar Investment Authority, Host Sponsor Qatari Diar Real Estate Investment Company
facilitates infrastructure and socio-economic development in the wake of Qatar's phenomenal economic growth, managing the creation and co-ordination of financially sound property development and investment opportunities that span the globe.
NYSE: PPS), an Atlanta-based real estate investment trust; Skyrise Properties, a Dallas-based commercial real estate company; and Greenway Investment Company
, a Dallas-based commercial real estate investment company
, the 14.
The Special Collections Reading Room has been renamed the Paulson Reading Room in honor of Paulson Investment Company
We view Sovereign Investment Company
as an important partner in the execution of our real estate fee and leasehold sale/leaseback program," said Chris Hall, senior vice president-strategic business development at Rite Aid Corporation.
Jeff Hoppen, chief financial officer of Sovereign Investment Company
, says that the deal is an excellent example of the value Sovereign brings to the table.