And just when everyone finally understood that REITs were simply corporate entities formed to provide the market with a vehicle for real estate investment and property owners and managers with access to capital, the UPREIT
transactions, (umbrella partnership REIT), provide a tax-deferred exit strategy for owners of real estate who might otherwise recognise a significant taxable gain in a cash sale of a highly appreciated property with a low tax basis.
This work proved to be a turning point in the modern REIT era, with the UPREIT
structure paving the way for the tax advantaged initial public offerings of a large number of widely respected private real estate operating companies.
Finally, even where the REIT itself does not meet the PHC ownership test, TRSs or lower-tier REITs may meet it if they are owned through an UPREIT
operating partnership or if the REIT that owns them is a partner in any partnership.
is an umbrella partnership formed by a REIT to own, directly or indirectly, all the assets of the REIT.
Example 14: A publicly traded umbrella partnership real estate investment trust (UPREIT
) has an affiliated umbrella partnership, UP.
Year to date, BNL has raised USD 190.2 m in new equity, including dividend reinvestment and one UPREIT
Certain investment strategies are designed to take advantage of [section] 721 including an operating partnership (OP) created by a Real Estate Investment Trust (REIT) sometimes referred to as an "Umbrella Partnership" or UPREIT
. In exchange for the property contributed to the UPREIT
under [section] 721, the investor receives units in the operating partnership (OP Units).
Separately, the company mentioned that in other corporate filings, it amended certain organisational documents that permit it to adopt an "umbrella partnership" or UPREIT
structure as well, effective as of 1 April 2018 as well.
This was an UPREIT
transaction of the 100 percent interest in the property.
It is a Maryland real estate investment trust and conducts its business through an UPREIT
structure in which its properties are owned by the Operating Partnership, directly or through limited partnerships, limited liability companies or other subsidiaries.
Comfort & Sons of New York City for $85.5 million; and in an unusual UPREIT
transaction, Boston-based 1055 Stamford Associate's sale of 1055 Washington Boulevard in Stamford to Reckson Associates for $21.6 million in cash and the issuance of 465,845 class-C Common units of a limited partnership interest, valued at $24 per unit.