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27. Assume a building, owned by a REIT, increases in value and the REIT that owns it sells the building for $120 million and then

27. Assume a building, owned by a REIT, increases in value and the REIT that owns it sells the building for $120 million and then makes a capital gain distribution to its shareholders. Which of the following is true regarding?

A U.S. individual investor's tax treatment:

The gain on the sale will be taxed at the ordinary income tax rate.

  1. The gain on the sale will be taxed at the capital gain tax rate.
  2. The gain on the sale will be taxed as UBTI and subject to the corporate tax rate.
  3. The gain on the sale will be taxed as ECI and subject to the highest applicable tax rate.
  4. There is no tax on the capital gain distribution at the shareholder level.
  5. None of the above.

A tax-exempt investor's tax treatment:

  1. The gain on the sale will be taxed at the ordinary income tax rate.
  2. The gain on the sale will be taxed at the capital gain tax rate.
  3. The gain on the sale will be taxed as UBTI and subject to the corporate tax rate.
  4. The gain on the sale will be taxed as ECI and subject to the highest applicable tax rate.
  5. There is no tax on the capital gain distribution at the shareholder level.
  6. None of the above.

A non-US investor's tax treatment:

  1. The gain on the sale will be taxed at the ordinary income tax rate.
  2. The gain on the sale will be taxed at the capital gain tax rate.
  3. The gain on the sale will be taxed as UBTI and subject to the corporate tax rate.
  4. The gain on the sale will be taxed as ECI and subject to the highest applicable tax rate.
  5. There is no tax on the capital gain distribution at the shareholder level.
  6. None of the above.

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