Name
Partnership Taxation: Real Estate and Sovereign Wealth: Inbound Investment in a Shifting Landscape
Date & Time
Wednesday, January 13, 2027, 10:30 AM - 11:45 AM
Description

Cross-border capital's appetite for U.S. real estate is running through a fast-moving—and lately taxpayer-friendly—policy landscape. The December 2025 final Section 892 regulations simplified the sovereign exemption—later softened further by Treasury's May 2026 grandfathering and transitional relief—while October 2025 proposed rules rolled back the 2024 domestically-controlled-REIT look-through. This panel maps those developments, alongside OBBBA's domestic provisions—restored bonus depreciation, the EBITDA-based Section 163(j) limitation, and qualified production property—and how sovereign funds, foreign pension funds, and their sponsors are restructuring as the rules reset.

David Friedline