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Real Estate Investment Trusts Royalty trusts, in Finance, are classic flow-through investments vehicles. The trust, like a mutual fund, holds a portfolio of assets, which can be anything from producing oil and gas wells to power generating stations to interests in land. The net cash flow, i.e. the total cash flow minus revenues, is passed on to the unit-holders as distribution.

The purpose of a Real Estate Investment Trusts is to reduce or eliminate corporate income taxes. In the United States, where they are generally more widespread as investment vehicles, Real Estate Investment Trusts pay little or no federal income tax but are subject to a number of special requirements set forth in the Internal Revenue Code, one of which is the requirement to distribute annually at least 90 percent of their taxable income in the form of dividends to shareholders.

Real Estate Investment Trusts are, therefore, a special type of royalty trust. They specialize in real property, anything from office buildings to long-term care facilities. For illiquid assets like real estate, closed-end funds of this type make good sense. Open-end or ‘mutual' real estate funds are subject to new money and redemption problems, entirely absent in closed-end trusts. The first Real Estate Investment Trust was introduced in the United States in 1960. The vehicle was designed to facilitate investments in large-scale income-producing real estate by smaller investors. The US model was simple, enabling small investors to acquire equity interests in vehicles holding large-scale commercial property.

But the birth of Real Estate Investments Trusts as a mass investment vehicle can be traced directly to the liquidity crisis encountered by open-end real estate mutual funds all the way back to 1991-92, during the slowdown of real estate that characterized those years. Faced with redemption demands on the part of unit-holders, real estate mutual funds were presented with the unpalatable option of selling valuable real properties into a distressed market to raise cash. Many of them, therefore, chose to close off redemptions and converted into Real Estate Investment Trusts, since then most commonly known as REIT's. Only a few open-end real estate mutual funds continue to own real estate directly. Most now invest in shares of real estate-related companies.

The typical REIT usually distributes about 85 to 95 percent of its income (rental income from properties) to the shareholders, usually on a quarterly basis. This income gets a special tax break, because REIT's shareholders are entitled to a deduction for the pro-rata share of capital cost allowance (depreciation on the real properties). As a result, a high percentage of the distributions are normally tax-deferred. However, the amount will vary from year to year and will differ depending on the particular REIT.


As with royalty trust, the value of tax-deferred income will reduce the adjusted cost base of the shares owned. For example, if an investor purchases 1,000 units at $15.50 per unit, receives $3,000 ($3.00 per share) in aggregate tax-deferred distribution over time, and the sells the shares for $17.50 each, the capital gain will be calculated as follows:

[1,000 x ($17.50 - $15.50 + $3.00)] = $5,000 before adjustments for commissions. In Canada, this gain will be subjected to capital gain treatment, so only 50 percent or $2,500 will be included in income and taxed accordingly. In fact, Canada allows preferential tax treatment to REIT's by making them RRSPeligible and by not considering them foreign property (which would taxed at a higher rate), so long as the real estate portfolio does not contain non-Canadian property in excess of the allowable limit.

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Real estate investment trusts