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Under U.S. Federal income tax law, a real estate investment trust (REIT) /ˈriːt/ is "any corporation, trust or association that acts as an investment agent specializing in real estate and real estate mortgages" under Internal Revenue Code section 856.[1] The rules for federal income taxation of REITs are found primarily in Part II (sections 856 through 859) of Subchapter M of Chapter 1 of the Internal Revenue Code. Because a REIT is entitled to deduct dividends paid to its owners, a REIT may avoid incurring all or part of its liabilities for U.S. federal income tax. To qualify as a REIT, an organization makes an "election" to do so by filing a Form 1120-REIT with the Internal Revenue Service, and by meeting certain other requirements. The purpose of this designation is to reduce or eliminate corporate tax, thus avoiding double taxation of owner income. In return, REITs are required to distribute at least 90% of their taxable income into the hands of investors. A REIT is a company that owns, and in most cases, operates income-producing real estate. REITs own many types of commercial real estate, ranging from office and apartment buildings to warehouses, hospitals, shopping centers, hotels and even timberlands. Some REITs also engage in financing real estate. The REIT structure was designed to provide a real estate investment structure similar to the structure mutual funds provide for investment in stocks.[2]

REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges.

REITs can be classified as equity, mortgage, or a hybrid.

The key statistics to examine in a REIT are net asset value (NAV), funds from operations (FFO), and adjusted funds from operations (AFFO). In the period from 2008 to 2011, REITs faced challenges from both a slowing United States economy and the late-2000s financial crisis, which depressed share values by 40 to 70 percent in some cases.[3]

History

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Creation

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REITs were created in the United States when President Eisenhower signed into law the REIT Act title contained in the Cigar Excise Tax Extension of 1960.[4] REITs were created by Congress in order to give all investors the opportunity to invest in large-scale, diversified portfolios of income-producing real estate in the same way they typically invest in other asset classes – through the purchase and sale of liquid securities.

Since then, more than 20 countries around the world have established REIT regimes, with more countries in the works. The spread of the REIT approach to real estate investment around the world has also increased awareness and acceptance of investing in global real estate securities.[5]

A comprehensive index for the REIT and global listed property market is the FTSE EPRA/NAREIT Global Real Estate Index Series, which was created jointly in October 2001 by the index provider FTSE Group, the National Association of Real Estate Investment Trusts (NAREIT) and the European Public Real Estate Association.

As of mid-2012, the global index included 414 public real estate companies from 37 countries representing an equity market capitalization of about $1 trillion (with approximately 68% of that total from REITs).[6]

Evolution

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Around the time of their creation in 1960, the first REITs primarily consisted of mortgage companies. The industry experienced significant expansion in the late ‘60s and early 1970s. The growth primarily resulted from the increased use of mortgage REITs in land development and construction deals. The Tax Reform Act of 1976 authorized REITs to be established as corporations in addition to business trusts.

The Tax Reform Act of 1986 also impacted REITs. The legislation included new rules designed to prevent taxpayers from using partnerships to shelter their earnings from other sources. Three years later, REITs witnessed significant losses in the stock market.

Retail REIT Taubman Centers Inc. launched the modern era of REITs in 1992 with its creation of the UPREIT. In an UPREIT, the parties of an existing partnership and a REIT become partners in a new “operating partnership.” The REIT typically is the general partner and the majority owner of the operating partnership units, and the partners who contributed properties have the right to exchange their operating partnershipunits for REIT shares or cash.The industry struggled beginning in 2007 as the global financial crisis kicked in. In response to the global credit crisis, listed REITs responded by deleveraging and re-equitizing their balance sheets. Listed REITs and REOCs raised $37.5 billion in 91 secondary equity offerings, nine IPOs and 37 unsecured debt offerings as investors continued to act favorably to companies strengthening their balance sheets following the credit crisis.

A comprehensive index for the REIT and global listed property market is the FTSE EPRA/NAREIT Global Real Estate Index Series, which was created jointly in October 2001 by the index provider FTSE Group, the National Association of Real Estate Investment Trusts (NAREIT) and the European Public Real Estate Association (EPRA). As of mid-2012, the global index included 414 public real estate companies from 37 countries representing an equity market capitalization of about $1 trillion (with approximately 68% of that total from REITs).[7]

Africa

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Ghana

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REITs have been in existence in Ghana since 1994. The Home Finance Company, now HFC BANK, established the first REIT in Ghana in August 1994. HFC Bank has been at the forefront of mortgage financing in Ghana since 1993. It has used various collective investment schemes as well as corporate bonds to finance its mortgage lending activities. Collective Investment Schemes, of which REIT’s are a part, are currently regulated by the Securities and Exchange Commission of Ghana.

Nigeria

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In 2007, the Securities and Exchange Commission (SEC) issued the first set of guidelines for the registration and issuance of requirements for the operation of REITs in Nigeria as detailed in the Investment and Securities Act (ISA). The first REIT, the N50 billion Union Homes Hybrid Real Estate Investment Trust, was launched in September 2008.

Asia

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Australia

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Main article: Australian real estate investment trust

The REIT concept was launched in Australia in 1971. General Property Trust was the first Australian real estate investment trust (LPT) on the Australian stock exchanges (now the Australian Securities Exchange). REITs which are listed on an exchange were known as Listed Property Trusts (LPTs) until March 2008, distinguishing them from private REITs which are known in Australia as Unlisted Property Trusts. They have since been renamed Australian Real Estate Investment Trusts (A-REITs) in line with international practice.[8]

There are now more than 70 A-REITs listed on the ASX, with market capitalization in excess of A$100bn.[8]

Australia is also receiving growing recognition as having the world’s largest REITs market outside the United States. More than 12 percent of global listed property trusts can be found on the ASX.[9]

Hong Kong

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REITs have been in existence in Hong Kong since 2005, when The Link REIT was launched by the Hong Kong Housing Authority on behalf of the Government. Since 2005, there have been 7 REIT listings as at July 2007, most of which, including Sunlight REIT have not enjoyed success because of low yield. Except for The Link and Regal Real Estate Investment Trust, share prices of all but one are significantly below IPO price. Hong Kong issuers' use of financial engineering (interest rate swaps) to improve initial yields has also been cited as having reduced investors' interest[10]

As of July 2012 there are nine REITs listed with a total market capitalization of approximately €15 billion which amounts to almost 2% of the total global REIT market capitalization. Two out of the nine listed REITs are also included in the EPRA index, an index published by the European Public Real Estate Association (EPRA). The current top five REITs in Hong Kong are The Link REIT with a total market capitalization of €8 billion, HUI XIAN REIT with a total market capitalization of €2.3 billion, Champion REIT with a total market capitalization of €1.8 billion, Fortune REIT with a total market capitalization of €1 billion and Regal Real Estate with a total market capitalization of €700 million.[11]

India

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As of January 2010, India was formulating legislation for REITs in the Indian real estate market. Once introduced, these Indian REITs (country specific/generic version I-REITs) will help individual investors enjoy the benefits of owning an interest in the securitised real estate market. The greatest benefit will be that of fast and easy liquidation of investments in the real estate market unlike the traditional way of disposing of real estate. The government and Securities and Exchange Board of India SEBI through various notifications is in the process of making it easier to invest in real estate in India directly and indirectly through foreign direct investment, through listed real estate companies and mutual funds.

Japan

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Japan is one of a handful of countries in Asia with REIT legislation (other countries/markets include Hong Kong, Singapore, Malaysia, Taiwan and Korea), which permitted their establishment in December 2001. J-REIT securities are traded on the Tokyo Stock Exchange, and most service providers of the J-REITs are Japanese real estate companies, Japanese conglomerates and foreign investment banks. [citation needed]

Since the burst of the real estate bubble in 1990, property prices in Japan have seen steady drops through 2004, with some signs of price stabilization and possibly price increase in 2005 and 2006. Some see J-REITs as a way to increase investment in the real estate market, although notable increases in asset values have not yet been realized.[citation needed]

A J-REIT (a listed real estate investment trust) is strictly regulated under the Law concerning Investment Trusts and Investment Companies (the "LITIC") and established as an investment company under the LITIC.

In addition to REITs, Japanese law also provides for a parallel system of special purpose companies which can be used for the securitization of particular properties on the private placement basis.

Malaysia

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The Bursa Malaysia (www.bursamalaysia.com) has 16 REIT listed with 5 Islamic REITS (syariah compliant - according to Islamic investment compliance).

Pakistan

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The Securities and Exchange Commission of Pakistan is in the process of implementing a REIT regulatory framework that will allow full foreign ownership, free movement of capital and unrestricted repatriation of profits. It will curb speculation in Pakistani real estate markets and gives access to small investors who want to diversify into real estate. The Securities and Exchange Commission of Pakistan is proposing a regulatory framework similar to that of Singapore and Hong Kong.[citation needed]

The Securities and Exchange Commission of Pakistan expects that about six REITs will be licensed within the first year, mainly large asset management companies. Pakistan has recently seen an outflow of investments by foreign real estate development companies, mostly based in Malaysia and Dubai.[12]

SECP has currently issued license to three parties namely, Arif Habib REIT Management Company, AKD REIT Management Company and Eden Developers REIT Management Company.

Philippines

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REITs in the Philippines will soon be available to the public after the Real Estate Investment Trust Act of 2009 (RA 9856) passed into law on December 17, 2009. Its Implementing Rules and Regulations were approved by the Securities and Exchange Commission in May 2010.

Singapore

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Commonly referred to as S-REITs, there are currently 20 REITs listed on the SGX, the first one to be set up being CapitaMall Trust [13] in July 2002. They represent a range of property sectors including retail, office, industrial, hospitality and residential. S-REITs hold a variety of properties in countries including Japan, China, Indonesia and Hong Kong, in addition to local properties.[14][15]

S-REITs are regulated as Collective Investment Schemes under the Monetary Authority of Singapore's Code on Collective Investment Schemes,[16] or alternatively as Business Trusts.[17]

S-REITs benefit from tax advantaged status.

United Arab Emirates

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The REIT legislation was introduced by Dubai International Financial Centre (DIFC) to promote the development of REIT’s in the UAE by passing The Investment Trust Law No.5 that went into effect on August 6, 2006.[citation needed] This restricts all 'true' REIT structures to be domiciled within the DIFC. The first REIT license to be issued will be backed by Dubai Islamic Bank with a REIT named 'Emirates REIT' headed up by the dot com entrepreneur, Sylvain Vieujot.[citation needed] The issue is that DIFC domiciled REIT's cannot acquire non-Freezone assets within the Emirate of Dubai. The only federally approved Freezone within the UAE is the DIFC itself so therefore we expect to see Emirates REIT focusing all of its attention within this zone. Outside of the zone properties are purchasable by local Gulf (GCC) passport holders only.[citation needed] With a lack of what property experts would call true 'A grade' property in Dubai the validity of a REIT in the UAE to be ultimately sold out in a public share format is highly unlikely.[citation needed]

Saudi Arabia

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Commonly referred to as Real Estate Investment Fund, the regulations were launched in July 2006 by CMA, The regulation did not allow the funds to be traded in the stock market and force all funds to be structured by a licensed Investment companies by CMA with a presence of a real estate developer and some other key persons.[18]

Europe

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Over the past few years new REIT regimes have been introduced in Europe to meet the growing demand from investors for tax efficient real estate investments vehicles, existing REIT regime in Europe have also been improved.[19] In Europe, the top-performing REIT and the largest publicly traded real estate company is Unibail-Rodamco SE.[20][21]

Bulgaria

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REITs were introduced in Bulgaria in 2004 with the so-called "Special Purpose Investment Companies Act". They are pass-through entities for corporate income tax purposes (i.e. they are not subject to corporate income tax), but are subject to numerous restrictions.[22]

Finland

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Finnish REITs were established in 2010, when 'the tax exemption law' (Laki eräiden asuntojen vuokraustoimintaa harjoittavien osakeyhtiöiden verohuojennuksesta, 299/2009)[23] was passed by the Finnish parliament. Together with the 'Law on Real Estate Funds' (Kiinteistörahastolaki, 1173/1997) [24] it enables the existence of tax efficient residential REITs.

Qualifications

  • REITs will have to be established as a public listed company (julkinen osakeyhtiö, Oyj) for this specific purpose. When the REIT is established the minimum equity is 5M€ and it has to be distributed over 5 separate investors.
  • Minimum holding period: 5 years.
  • At least 80% of its assets have to be invested in residential real-estate.
  • At least 80% of the REIT's gross revenues must come from residential rental income.
  • At least 90% of the REIT's taxable income, excluding unrealised capital gains, has to be distributed to its shareholders through dividends.
  • The corporation is income-tax-exempt, but the shareholders will have to pay individual income tax on the dividends.
  • Largest individual shareholder may own less than 10% of company shares (max. 30% till the end of 2013).

France

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The French acronym for REIT is SIIC. In France, Unibail-Rodamco is the largest SIIC.[25] Gecina is the second largest publicly traded property company in France, with the third highest asset value among European REITs.[26][27]

Germany

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Germany is also planning to introduce German REITs (short, G-REITs) in order to create a new type of real estate investment vehicle. Government fears that failing to introduce REITs in Germany would result in a significant loss of investment capital to other countries. Nonetheless there still is political resistance to these plans, especially by the social democratic party ('SPD').

A law concerning G-REITs was enacted 1 June 2007, and was retroactive to 1 January 2007:[28]

  • REITs will have to be established as a corporation "REIT-AG" or "REIT-Aktiengesellschaft".
  • At least 75% of its assets have to be invested in real-estate.
  • At least 75% of the G-REIT's gross revenues must be real-estate related.
  • At least 90% of the REIT's taxable income has to be distributed to its shareholders through dividends.
  • The corporation is income-tax-exempt, but the shareholders will have to pay individual income tax on the dividends.
  • Some restrictions apply on establishing residential REIT's

As of July 2012, there are four G-REITs listed with one company registered at the Federal Central Tax Office (Bundeszentralamt für Steuern) as pre-REIT. These four G-REITS are Alstria office REIT with a total market capitalization of €711 million, Hamborner with a total market capitalization of €321 million, Colonia Real Estate with a total market capitalization of €150 million and Fair Value REIT with a total market capitalization of €35 million. The German public real estate sector accounts for 0.21% of the total global real estate investment trust (REIT) market capitalization. Three out of the four G-REITS are also represented in the EPRA index, an index managed by the European Public Real Estate Association (EPRA).[29]

United Kingdom

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The legislation laying out the rules for REITs in the United Kingdom was enacted in the Finance Act 2006 and came into effect in January 2007 when nine UK property companies converted to REIT status, including five FTSE 100 members at that time: British Land, Hammerson, Land Securities, Liberty International and Slough Estates (now known as "SEGRO"). The other four companies were Brixton (now known as "SEGRO"), Great Portland Estates, Primary Health Properties and Workspace Group.[30]

British REITs have to distribute 90% of their income. They must be a close-ended investment trust and be UK resident and publicly listed on a stock exchange recognised by the Financial Services Authority.[citation needed] The European Public Real Estate Association in Brussels each year publishes a breakdown of the UK REIT structure requirements.[31]

To support the introduction of REITs in the UK, the REITs and Quoted Property Group was created by several commercial property and financial services companies. Other key bodies involved are the London Stock Exchange the British Property Federation and Reita. The Reita campaign was launched on 16 August 2006 by the REITs and Quoted Property Group, in order to provide a source of information on REITs, quoted property and related investments funds. Reita's aim is to raise awareness and understanding of REITs and investment in quoted property companies. It does this primarily through its portal www.reita.org, providing knowledge, education and tools for financial advisers and investors.[32]

Doug Naismith, managing director of European Personal Investments for Fidelity International, said: "As existing markets expand and REIT-like structures are introduced in more countries, we expect to see the overall market grow by some ten percent per annum over the next five years, taking the market to $1 trillion by 2010."[33]

The Finance Act 2012 brought five main changes to the REIT regime in the UK, being (i) the abolition of the 2% entry charge to join the regime - this should make REITs more attractive due to reduced costs; (ii) relaxation of the listing requirements - REITs can now be AIM quoted[34] (the London Stock Exchange’s international market for smaller growing companies) – making a listing more attractive due to reduced costs and greater flexibility; (iii) a REIT now has a three-year grace period before having to comply with close company rules (a close company is a company under the control of five or fewer investors); (iv) a REIT will not be considered to be a close company if it can be made close by the inclusion of institutional investors (authorised unit trusts, OEICs, pension schemes, insurance companies and bodies which are sovereign immune) - this makes REITs attractive Real Estate Investment Trusts; (v) the interest cover test of 1.25 times finance costs is not as onerous.

Boyd Carson of Sapphire Capital Partners LLP commented that "the most important of these advantages is the ability for REITs to be listed on the AIM and the abolition of the 2% entry charge to the regime is also a significant step forward."[35]

North America

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Canada

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See also: List of REITs in Canada

Canadian REITs were established in 1993. They are required to be configured as trusts and are not taxed if they distribute their net taxable income to shareholders. REITs have been excluded from the income trust tax legislation passed in the 2007 budget by the Conservative government. Many Canadian REITs have limited liability.[36] On December 16, 2010, the Department of Finance proposed amendments to the rules defining “Qualifying REITs” for Canadian tax purposes. As a result, “Qualifying REITs” are exempt from the new entity-level, “specified investment flow-through” (SIFT) tax that all publicly traded income trusts and partnerships are paying as of January 1, 2011.[37]

Mexico

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Mexico recently passed legislation to allow for the equivalent of REITs, known as FIBRAs (Fideicomiso de Infraestructura y Bienes Raíces), to be traded in the Mexican Stock Exchange. Like REITs legislation in other countries, companies must qualify as a FIRBRA by complying with the following rules:[38]

  • at lease 70% of assets must be invested in financing or owning of real estate assets, with the remaining amount invested in government-issued securities or debt-instrument mutual funds.
  • Acquired or developed real estate assets must be income generating and held for at least four years.
  • If shares, known as Certificados de Participación Inmobiliarios or CPIs, are issued privately, there must be more than 10 unrelated investors in the FIBRA.
  • The FIBRA must distribute 95% of annual profits to investors.

The first Mexican REIT was launched in 2011 and is called FIBRA UNO.[39]

United States

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See also: List of public REITs in the United States

In the United States, a REIT is a company that owns, and in most cases operates, income-producing real estate. Some REITs finance real estate. To be a REIT, a company must distribute at least 90 percent of its taxable income to shareholders annually in the form of dividends.[40]

To qualify as a REIT under U.S. tax rules, a company must:

  • Be structured as a corporation, trust, or association[41]
  • Be managed by a board of directors or trustees[42]
  • Have transferable shares or transferable certificates of interest[43]
  • Otherwise be taxable as a domestic corporation[44]
  • Not be a financial institution or an insurance company[45]
  • Be jointly owned by 100 persons or more[46]
  • Have 95 percent of its income derived from dividends, interest, and property income[47]
  • Pay dividends of at least 90% of the REIT's taxable income
  • Have no more than 50% of the shares held by five or fewer individuals during the last half of each taxable year (5/50 rule)
  • Have at least 75% of its total assets invested in real estate
  • Derive at least 75% of its gross income from rents or mortgage interest
  • Have no more than 25% of its assets invested in taxable REIT subsidiaries.

Because of their access to corporate-level debt and equity that typical real estate owners cannot access, REITs have a favorable capital structure. They are able to use this capital to finance tenant improvement costs and leasing commissions that less capitalized owners cannot afford.

South America

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Brazil

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REITs were introduced in Brazil in 1993 by the law 8668/93 and initially ruled by the instruction 205/94 and, nowadays, by instruction 472/08 from CVM (Comissão de Valores Mobiliários - which is the Brazilian equivalent of SEC). Locally they are described as "FII"s or "Fundos de Investimento Imobiliário". FII's dividends have been free of taxes for personal investors (not companies) since 2006, but only for the funds which have at least 50 investors and that are publicly traded in the stock market. FIIs, referred to as “REIT” to correspond with the similar investment vehicle in the US, have been used either to own and operate independent property investments, associated with a single property or part property, or to own several real properties (multiple properties) funded through the capital markets.[citation needed]

See also

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References

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  1. ^ CCH 2008 U.S. Master Tax Guide, paragr. 2326, page 681.
  2. ^ "UPREITs, Down-REITs And Other REIT Vehicles: Should You Go Along For The Ride?". FindLaw.com.
  3. ^ Carrick, Rob. "REITs battered down to eye-catching levels". ctv.ca. Retrieved 2008-12-08. {{cite news}}: Cite has empty unknown parameter: |coauthors= (help)
  4. ^ "REIT 50 Years Timeline". Reit.com. Retrieved 2012-12-18.
  5. ^ "Global Real Estate Investing". Reit.com. Retrieved 2012-12-18.
  6. ^ "EPRA/NAREIT Global Real Estate Index Series". FTSE. Retrieved 2012-12-18.
  7. ^ http://www.ftse.com/Indices/FTSE_EPRA_NAREIT_Global_Real_Estate_Index_Series/index.jsp
  8. ^ a b Mahipal Singh, Security Analysis with Investment and Portfolio Management, Isha Books 2011, page 145.
  9. ^ Baljeez Hbk, “Reits & remf”, http://www.slideshare.net/baljeez_hbk/reits-remf-real-estate , retrieved 28 January 2013
  10. ^ Tim LeeMaster & Yvonne Liu, "Swire considers Festival Walk reit", Page B1, South China Morning Post, July 12, 2007
  11. ^ So, KK. "Global REIT Survey 2012: Hong Kong". Global REIT Survey. European Public Real Estate Association (EPRA). Retrieved 2013-02-27.
  12. ^ Pakistan ready to allow REITs - It aims to draw $3 billion from overseas investors in 5 years
  13. ^ Capitamall.com
  14. ^ SGX REIT Data
  15. ^ AsiaOne: Bright outlook for S-Reit market
  16. ^ MAS: Code of Collective Investment Schemes
  17. ^ Gov.sg
  18. ^ http://cma.gov.sa/Ar/Documents/lahiya%20sanadeek%20(aqaree).pdf
  19. ^ REITs: a comparative approach throughout Europe, CMS Legal
  20. ^ Stephen Wilmot, Unibail-Rodamco: Europe's top Reit, Investors Chronicle, 28 June 2012
  21. ^ Simon Packard, Unibail-Rodamco to Enter Germany in Perella Weinberg Deal, Bloomberg, 14 June 2012
  22. ^ "Real Estate Investments in Bulgaria" (PDF). Retrieved 2008-01-01.
  23. ^ "FINLEX ® - Ajantasainen lainsäädäntö: 24.4.2009/299". Finlex.fi. Retrieved 2012-12-18.
  24. ^ Kiinteistörahastolaki; http://www.finlex.fi/fi/laki/ajantasa/1997/19971173
  25. ^ European Investment Commentary Cohen & Steers, November 2011
  26. ^ "Gecina largest office space in France".
  27. ^ "Gecina Reports First-Half Profit as French Company's Properties Gain Value". 2010-07-28.
  28. ^ Alan O'Sullivan (1 June 2007). "G-Reit news for German property". citywire.co.uk. Archived from the original on 2007-09-27. Retrieved 2007-06-30.
  29. ^ Hackemann, Tim. "Global REIT Survey 2012: Germany". Global REIT Survey 2012. European Public Real Estate Association. Retrieved 20 February 2013.
  30. ^ "REITs (Real Estate Investment Trusts)". ShareWorld. Retrieved 5 February 2012.
  31. ^ Rowe, Rosalind. "Global REIT Survey 2012: UK". Global REIT Survey 2012. European Public Real Estate Association. Retrieved 19 April 2013.
  32. ^ "Reita - UK REITs - Real Estate Investment Trust and property investment portal". Bpf.org.uk. Retrieved 2012-12-18.
  33. ^ http://olympiacapitalresearch.com/REITs.html
  34. ^ UK REITS SapphireCapitalPartners.co.uk
  35. ^ Sapphire Capital Partners LLP
  36. ^ Mark Rothschild (November/December 2005). "Spotlight on North America/Canada". Reit.com. Retrieved 2006-10-17. {{cite web}}: Check date values in: |date= (help)
  37. ^ David Dittman. "REIT Investing, Canadian Style". InvestingDaily.com. Retrieved 2011-01-14.
  38. ^ Luis F. Moreno Trevino, Julio Planas Vidal. "The Infrastructure and Real Estate Trust in Mexico (FIBRA)". Haynes and Boone. Retrieved 2013-05-27.
  39. ^ "Mexican REIT FIBRA Uno Raises $300M". Institutional Investor. Retrieved 2013-05-27.
  40. ^ "Real Estate Investment Trusts (REITs)". U.S. Securities and Exchange Commission. Retrieved 16 March 2012.
  41. ^ Internal Revenue Code Sect. 856(a)
  42. ^ Internal Revenue Code Sect. 856(a)(1)
  43. ^ Internal Revenue Code Sect. 856(a)(2)
  44. ^ Internal Revenue Code Sect. 856(a)(3)
  45. ^ See Internal Revenue Code Sect. 856(a)(4). See also Internal Revenue Code Sect. 582(c)(2) (defining financial institutions for these purposes); Internal Revenue Code Sect. 801 et. seq. (defining insurance companies for these purposes).
  46. ^ Internal Revenue Code Sect. 856(a)(5).
  47. ^ Internal Revenue Code Sect. 856(c)(2)
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