HOUSE_OVERSIGHT_026829

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From: Richard Kahn 
Sent: 12/24/2015 12:52:15 AM 
To: Jeffrey Epstein [jeevacation@gmail.com] 
Subject: Fwd: Alert: FIRPTA and REIT Reform Provisions in the New Tax Law Open Door to Increased Foreign Investment in 
U.S. Real Property Interests 
Importance: High 
Richard Kahn 
HBRK Associates Inc. 
575 Lexington Avenue, 4th Floor 
New York, NY 10022 
Tel 
Fax 
Cell 
Begin forwarded message: 
From: Sadis & Goldberg Tax Group < 
Date: December 23, 2015 at 3:02:13 PM EST 
To 
Subject: Alert: FIRPTA and REIT Reform Provisions in the New Tax Law Open Door to Increased 
Foreign Investment in U.S. Real Property Interests 
Reply-To: 
TAX ALERT 
DECEMBER 23, 2015 
FIRPTA and REIT Reform Provisions in 
New Tax Law Open Door to Increased 
Foreign Investment in U.S. Real 
Property Interests 
For further information about this Alert, 
please contact: 
Steven Etkind 
Partner 
HOUSE OVERSIGHT 026829 
212.573.8412 
setkind@sglawyers.com 
Alex Gelinas 
Partner 
212.573.8159 
agelinas@sglawyers.com 
Please feel free to discuss any aspect of 
this Alert with your regular Sadis & 
Goldberg contact or with any of the 
partners whose names and contact 
information can be found at the end of 
the Alert. 
On December 18, 2015, President Obama signed into law a bill that significantly reforms the provisions 
of the Internal Revenue Code that were originally added 35 years ago by the Foreign Investment in 
Real Property Tax Act of 1980 (FIRPTA). The Protecting Americans from Tax Hikes Act of 2015 (the 
"PATH Act") also includes extensions of a number of tax relief provisions that expired at the end of 
2015. The PATH Act makes foreign capital investment in U.S. real estate, energy and infrastructure 
assets more attractive by expanding certain exemptions from FIRPTA and clarifying the application of 
certain FIRPTA provisions to REITs and their shareholders. 
I. FOREIGN PENSION FUNDS EXEMPTED FROM FIRPTA TAXATION 
One of the most significant provisions of the PATH Act is the addition of a com

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