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Under US federal income tax law and, in particular, Section 897 of the Internal Revenue Code of 1986, as amended (the so-called “FIRPTA” rules), gain from the disposition of US real property interests is treated as income effectively connected with the conduct of a US trade or business, and therefore such gain is subject to US federal income tax (the “FIRPTA tax”).
A “US real property interest” is broadly defined as a direct interest in real property located in the United States or the Virgin Islands, an interest in a partnership meeting certain US real property interest ownership tests, or an interest in a US corporation that has been a “US real property holding corporation” at any time within the 5-year period ending on the date of the disposition of such interest.
The conditions described in paragraphs (1) to (4), inclusive, of subsection (a) must be met during the entire taxable year, and the condition described in paragraph (5) must exist during at least 335 days of a taxable year of 12 months, or during a proportionate part of a taxable year of less than 12 months.
897(h)(1) suggests an intent to treat liquidating distributions from DCRs as exempt from U. 897(h)(1) suggests that Congress viewed capital gain dividends, rather than liquidating distributions, as the tax base for Code Sec. The Congressional Report accompanying the original FIRPTA legislation states that, under Code Sec. The rule does not, however, permit any liquidating distributions to be treated as “capital gain dividends.” This complies with the general treatment of liquidating distributions under Subchapter C of the Code as an amount paid by a liquidating corporation to its shareholders in exchange for their stock rather than a dividend.
has served as our Chief Financial Officer since September 2014. Milligan served as the Company’s Executive Vice President of Corporate Finance and Capital Markets since July 2014, before which time he served as the Senior Vice President of Corporate Finance from January 2013 to July 2014 and the Director of Finance from January 2012 to January 2013. has served as our Executive Vice President – Acquisitions since July 2009. Engstrom served as an independent consultant to us providing acquisition and asset management support. Engstrom has over 24 years of experience in organizational leadership, acquisitions, management, asset management, project management, leasing, planning, facilities development, financing, and establishing industry leading real estate and facilities groups. Engstrom was the Chief Executive Officer of Insite Medical Properties, a real estate services and investment company. Engstrom served as a Manager of Real Estate Services for Hammes Company and created a new business unit within the company which was responsible for providing asset and property management. Engstrom also served as a hospital administrator of Good Samaritan Hospitals from 1987 to 1995 and as a Vice President of PM Realty Group from 1995 to 1998. Prior to joining Glenborough, from August 2005 to August 2006, Ms. has served as an independent director of the Company since September 2006. Blair served as the Chief Executive Officer, President and Chairman of the board of directors of Golf Trust of America, Inc. (NYSE MKT LLC: PTX)) from the time of its formation as a REIT and initial public offering in 1997 until his resignation and retirement in November 2007. Blair managed the acquisition, operation, leasing and disposition of the assets of the portfolio. Blair served as Executive Vice President, Chief Operating Officer and General Counsel for The Legends Group. Blair was responsible for all aspects of operations, including acquisitions, development and marketing. Blair was the managing partner at Blair Conaway Bograd & Martin, P. has served as an independent director of the Company since September 2006. De Wald was with the international accounting and auditing firm of KPMG, LLP, where he served at various times as an audit partner, a member of their board of directors and the managing partner of the Orange County, Los Angeles, and Chicago offices. De Wald has served as Chairman and director of both the United Way of Greater Los Angeles and the United Way of Orange County California. During his tenure with Candlewood Hotel Company, Inc., Mr. Peterson & Associates in Houston, Texas, providing counsel to select clients on leadership, management, governance and strategy, and is the author of The Mathis Maxims, Lessons in Leadership. Mathis held numerous leadership positions in organizations charged with planning and directing the future of healthcare delivery in the United States. Mathis was the founding President and Chief Executive Officer of The Methodist Hospital System in Houston, Texas, having served that institution in various executive positions for 27 years, including the last 14 years as Chief Executive Officer before his retirement in 1997. From October 1999 to December 2001, he was a partner in Warmington Wescombe Realty Partners in Costa Mesa, California, where he focused on real estate investments and financing strategies. Wescombe was a partner with Ernst & Young, LLP (previously Kenneth Leventhal & Company) from 1970 to 1999. During Foss’s career at GE he held many positions, the last of which was President, Olympic Sponsorship and Corporate Sales, a post he held from 2003 until his retirement in 2013.
degree in Accounting and Finance from Kent State University. From June 2003 to July 2007, he served in various corporate finance capacities at General Electric. Milligan holds a BS degree in Finance and Economics from Arizona State University and an MBA degree from the University of Chicago. has served as our Executive Vice President – Asset Management since December 2011. Houghton served as our Senior Vice President of Asset Management and Finance. Houghton served as our Vice President of Asset Management and Finance. Houghton comes from a varied background with experience in asset and joint venture management, acquisitions, dispositions, and corporate cash modeling and valuation. Houghton served as the Manager of Joint Ventures for Glenborough LLC in San Mateo, California, where she actively managed over two million square feet of retail/office properties and 400 acres of development land. has served as our SVP, Acquisitions since May 2016. Atkinson served as the Company’s Director of Acquisitions from September 2012 – May 2016. Atkinson joined the Company in 2012 and comes from a focused background in medical office and general office real estate investments. Atkinson served JDM Partners in her position as Real Estate Investment Specialist from June 2010 – September 2012. Atkinson was a medical office and general office investment broker for Grubb & Ellis BRE Commercial. Atkinson holds a BS degree in Finance from Arizona State University. He previously served as our Director of Financial Planning & Analysis since December 2013 and Assistant Controller since July 2012, when he joined the Company. Gershenson previously had served in various roles at BDO USA, LLP (formerly BDO Seidman, LLP) between October 2003 and June 2012, ultimately achieving the title of Senior Manager of Assurance Services, where he was focused on audits of public and private enterprises in the real estate, financial services, and insurance industries. Gershenson is a Certified Public Accountant in the State of California (inactive) and holds a B. degree in Accountancy from California State University, Northridge. degree in Business from Indiana University in Bloomington, Indiana and a Juris Doctorate degree from the University of North Carolina School of Law. Blair is a member of the American Bar Association and the North Carolina Bar Association. Until November of 2008, when he completed a process of dissolution, he served for five years as the Chief Executive Officer of WCH, Inc., formerly Candlewood Hotel Company, Inc., having served as its Executive Vice President, Chief Financial Officer and Secretary since 1995. Since 1998 he has served as an executive consultant with D. He is also director, Chief Financial Officer and Treasurer of the Arnold and Mabel Beckman Foundation, a nonprofit foundation established for the purpose of supporting scientific research. from December 2001 to January 2008 and has served as chairman of the trustees of G REIT Liquidating Trust since January 2008. He returned to GE in November of 2013, joining the GE Healthcare team to be responsible for the GE/NFL brain research effort which he was instrumental in starting before his retirement.
person is generally not subject to FIRPTA (or other U. The stated purpose of Notice 2007-55 was to discuss what the IRS viewed as the inappropriate treatment by foreign governments of certain distributions from DCRs to such foreign governments as not being subject to tax under Code Sec. 897(h)(1) includes a liquidating distribution from a DCR attributable to gain from the sale or exchange of a USRPI.
897(h)(1) should not apply to liquidating distributions from DCRs to non-U. 897(h)(1), and that such section only applies to non-liquidating distributions, and not to liquidating distributions. 897(h)(1) did not apply to distributions in complete liquidation of a DCR to such non-U. taxpayer and (ii) issue regulations to clarify that the term “distribution” under Code Sec.
Under Notice 2007-55, discussed below, the IRS stated in part that it would challenge any assertion by a taxpayer that Code Sec. However, for the reasons set forth below, many tax professionals believe that Notice 2007-55 incorrectly interprets Code Sec.