Julanne Allen, principal, national tax services, at PwC, sat down for a video interview at Nareit’s REITwise: 2026 Educational Conference in Hollywood, Florida, March 24-26.
Allen explained that the biggest REIT tax challenges often come from everyday operations—not major deals. Internal teams may make well-intentioned but non-compliant decisions, she noted. “Smart people making smart decisions… aren’t REIT compliant decisions” without proper oversight."
She emphasized proactive planning for taxable REIT subsidiaries (TRSs), with clear agreements and ongoing monitoring. For related-party transactions, strict arm’s-length standards and updated transfer pricing are essential.
Meanwhile, new REITs face hurdles meeting income and asset tests, especially early on with limited activity, and must carefully track capital deployment, Allen said.