RHT was established and listed on the Singapore Exchange in 2012 when Fortis listed 15 clinical establishments (out of which 4 are new and `greenfield') and 2 hospitals, in a business trust
, RHT Health Trust on the Singapore Exchange raising S$510 million (USD 372 million).
Electing small business trusts
, which are usually treated as two separate trusts, have their adjusted gross income determined as if they were one trust for purposes of this tax.
The HPH Trust is the world's first publicly listed container port business trust
MCITIC invests in approximately 40-50 of the highest quality income trusts and is currently weighted with around 40-45% in oil & gas royalty trusts, 30-35% in business trusts
, 15-20% in REITS and 0-5% in pipeline & power trusts.
The Tax Court also found that the transfer of assets to the business trusts
satisfied the requirement for full and adequate consideration in money or money's worth following the reasoning in Bongard:
Because of the many newly created or converted S corporations, many letter rulings, notices, proposed regulations and revenue procedures reflected the 1996 legislative changes regarding qualified subchapter S subsidiaries (QSSSs), qualified subchapter S trusts (QSSTs) and electing small business trusts
(ESBTs); in addition, Rev.
Identical Letter Rulings 9328035 through 9328037 approved the nontaxable merger of RICs organized as business trusts
. The letter rulings applied the nontaxable property transfer provision of Sec.