Chris Mangin, Jr., associate, tax, at Paul Hastings LLP, sat down for a video interview at Nareit’s REITwise: 2026 Instructional Convention in Hollywood, Florida, March 24-26.
Mangin defined that cross-border tax has develop into more and more necessary for REITs as a consequence of a surge in demand for capital—particularly for infrastructure, AI, and information heart initiatives. With public markets generally limiting massive capital raises, REITs are turning to non-public capital, joint ventures, and institutional funding, a lot of it coming from abroad traders and sovereign wealth funds. These traders require deal constructions that protect key tax advantages, notably Part 892 exemptions.
Mangin highlighted current Treasury actions that might help inbound funding. The reversal of the controversial domestically managed REIT rule removes a barrier for international traders, whereas proposed Part 892 laws purpose to make clear when traders preserve tax-exempt standing. Nevertheless, some elements—similar to steerage round “efficient management” and customary minority protections—have created uncertainty available in the market, although changes are anticipated.
On broader coverage traits, Mangin famous that whereas proposals like Part 899 initially alarmed traders, they seem to have been extra of a negotiating tactic. Total, he sees a constructive authorities strategy centered on attracting international capital, recognizing its significance in funding large-scale U.S. actual property and know-how infrastructure investments.
