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Summary and key insights: IRS proposed regulations on QIEs

Dec 16, 2025 · 1 min read

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Overview:

Treasury and the IRS proposed regulations REG-109742-25 that would significantly change the rules for determining if a Qualified Investment Entity (QIE), like a Real Estate Investment Trust (REIT) or Regulated Investment Company (RIC), is “domestically controlled" under Sec. 897. The main change is the removal of the “domestic corporation look-through rule" from the 2024 final regulations.

Background:

  • Under Sec. 897, gain or loss from a nonresident alien or foreign corporation's U.S. Real Property Interest (USRPI) disposition is generally

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Topics

Tax

Subtopics

C Corporation Income Taxation
International Tax
Tax Policy & Regulatory Change
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