Update on Structure Review and Sales Target for 2025

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Stock US Masters Residential Property Fund (URF.ASX)
Release Time 28 Jan 2025, 9:57 a.m.
Price Sensitive Yes
 US Masters Residential Property Fund provides update on structure review and sales target for 2025
Key Points
  • Reclassification of US vehicle from REIT to taxable C-Corp structure
  • Adoption of formal plan of liquidation to be completed by 31 December 2028
  • Sales target for 2025 calendar year in the range of US$200 to $225 million
Full Summary

The Board of Directors of US Masters Residential Property Group (the Group) is pleased to announce that the Group has completed a review of the Group's US structure to ensure repatriations of net proceeds from the sales program are undertaken in the most tax efficient manner. On 28 January 2025, the Trustees of US Masters Residential Property (USA) Fund (US REIT or US Vehicle) agreed to reclassify the US Vehicle from its existing REIT structure to that of a taxable Corporate (C-Corp) structure for US tax purposes with an effective date of 1 January 2025. At the same time, the Trustees agreed to adopt a formal plan of liquidation which is expected to be completed by 31 December 2028 (the 'Liquidation Period'). The changes in structure of the US Vehicle do not impact the ongoing operations of the Australian entities or of the Group as a whole. Under the previous REIT structure, the Group was subject to a 15% withholding tax on taxable gains repatriated to Australia. The new C-Corp structure will subject the Group's US operations to US corporate taxes, but historical losses can be used to reduce the amount of corporate taxes expected to arise on the sell down of the portfolio. The future repatriation of funds to Australia made in connection with the US Vehicle's plan of liquidation are considered 'liquidating dividends' and not subject to withholding tax. The Group's total US tax exposure over the course of the sell down period will be impacted by several factors, and the Group estimates the net deferred tax liability will be reduced to less than US$5 million on the assumption all real estate assets are sold within the Liquidation Period. The sales target for the 2025 calendar year is in the range of US$200 to $225 million, signifying the commitment to executing on the asset sales program to return capital to investors as efficiently and expeditiously as possible.

Guidance

The sales target for the 2025 calendar year is in the range of US$200 to $225 million.