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Attorneys
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IRS Rules that Long Position in a Swap Referencing a Broad-Based US Real Property Index is Not a US Real Property Interest for FIRPTA PurposesJuly 8, 2008Ameek Ashok Ponda was quoted in the July 8, 2008 issue of The Hedge Fund Law Report. The article entitled "IRS Rules that Long Position in a Swap Referencing a Broad-Based US Real Property Index is Not a US Real Property Interest for FIRPTA Purposes." discusses how the IRS published Revenue Ruling 2008-31, holding that a long interest in a swap referencing a broad based index of U.S. Real Property is not a U.S. Real Property interest (USRPI) within the meaning of the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA).
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