Section 1446 (f)

NO WITHHOLDING TAX IN RELATION TO SECTION 1446(f) UNDER U.S. INTERNAL REVENUE CODE

  • United Hampshire US REIT (“UHREIT”) has provided a Qualified Notice on 1 Jan 2023 on its website to formally state that UHREIT is not engaged in a trade or business within the United States
  • Therefore the sale of transfer of UHREIT units by unitholders as well as distributions from UHREIT will not be subject to Section 1446(f) withholding
  • Brokers who effect a transfer of UHREIT units are not required to withhold the Section 1446(f) withholding tax
  • Unitholders are not required to file a U.S. federal income tax return or apply for a U.S. tax identification number solely based on the Section 1446(f) withholding tax

United Hampshire US REIT Management Pte. Ltd. in its capacity as manager (the “Manager”) of United Hampshire US Real Estate Investment Trust (“UHREIT” or the “REIT”), confirms that UHREIT is not engaged in a U.S. trade or business. Upon the advice of our tax advisor, the Manager will be providing a notice in the manner required by the regulations (“Qualified Notice”), and accordingly the disposition of UHREIT units by unitholders as well as distributions from UHREIT will not be subject to Internal Revenue Code (the “Code”) Section 1446(f) withholding. UHREIT intends to continue to operate in a manner that will not cause it to be treated as engaged in a U.S. trade or business.

The Manager has posted the formal Qualified Notice on its website on 1 January 2023, the date on which the final regulations and Section 1446(f) withholding tax become effective. The Qualified Notice will be valid for a 92 day period from its posting date. The Manager intends to issue a new Qualified Notice on a quarterly basis.

Therefore the sale of transfer of UHREIT units by unitholders as well as distributions from UHREIT will not be subject to Section 1446(f) withholding and brokers who effect a transfer of UHREIT units are not required to withhold the Section 1446(f) withholding tax. Furthermore, unitholders are not required to file a U.S. federal income tax return or apply for a U.S. tax identification number solely based on the Section 1446(f) withholding tax.

Date Title Download
1 Jan 2023 United Hampshire US REIT Section 1446(f) Qualified Notice - 1 January 2023 to 31 March 2023
16 Dec 2022 United Hampshire US REIT Section 1446(f) Qualified Notice (Draft)
16 Dec 2022 No Withholding Tax In Relation To Section 1446(f) Under U.S. Internal Revenue Code – Qualified Notice
27 Oct 2022 No Withholding Tax In Relation To Section 1446(f) Under U.S. Internal Revenue Code
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