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S. Rept. 114-25 1 (2015-04-14)

handle is hein.congrecreports/crptxsgy0001 and id is 1 raw text is: AUT-ENTICATED US. GOVERNMENT INFORMATION GP Calendar No. 48 114TH CONGRESS REPORT 1st Session SENATE 114-25 REAL ESTATE INVESTMENT AND JOBS ACT OF 2015 APRIL 14, 2015.-Ordered to be printed Mr. HATCH, from the Committee on Finance, submitted the following REPORT [To accompany S. 915] The Committee on Finance, having considered an original bill, S. 915, to amend the Internal Revenue Code of 1986 to exempt certain stock of real estate investment trusts from the tax on foreign in- vestments in United States real property interests, and for other purposes, having considered the same, reports favorably thereon without amendment and recommends that the bill do pass. CONTENTS Page I. LEGISLATIVE BACKGROUND ..................................................................... 2 II. EXPLANATION OF THE BILL ..................................................................... 3 A. Background and Present Law Relating to Real Estate Investment Trusts (REITs), Regulated Investment Companies (RICs), and the Foreign Investment in Real Property Tax Act (FIRPTA) ......... 3 B. Provisions Relating to REITs, RICs, and FIRPTA (secs. 1 through 7 of the bill, secs. 897, 1445, 245, and new sec. 6039B of the C ode) ................................................................................................... 10 1. Publicly traded REITs and certain publicly traded qualified shareholder entities that hold REIT stock ................................ 10 2. Domestically controlled definition ................................................ 12 3. Increase 10 percent FIRPTA withholding to 15 percent ............ 13 4. Required notification of FIRPTA status as a USRPHC, pre- sumption of foreign control of qualified investment entities, and penalty for failure to disclose FIRPTA status ................... 13 5. Require FIRPTA withholding by brokers ..................................... 16 6. Cleansing rule not applicable to RICs or REITs ......................... 17 7. Dividends derived from RICs and REITs ineligible for deduc- tion for U.S. source portion of dividends from certain foreign corporations ................................................................................. 17 C. Increase Continuous Levy Authority on Payments to Medicare Providers and Suppliers (sec. 9 of the bill and sec. 6331 of th e C ode) ............................................................................................. 18 49-010

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