FINAL QUALIFIED NOTICE ON NON-APPLICABILITY OF US WITHHOLDING TAX UNDER
SECTION 1446(f) OF UNITED STATES INTERNAL REVENUE CODE TO NON-US UNITHOLDERS
OF KEPPEL PACIFIC OAK US REIT
Keppel Pacific Oak US REIT Management Pte. Ltd., as manager of Keppel Pacific Oak US REIT (“KORE”,
and the manager of KORE, the “Manager”), wishes to refer to its announcement dated 2 December 2022
(the “Announcement”) clarifying that the US withholding tax under the final regulations (the “Final
Regulations”) of Section 1446(f) of the US Internal Revenue Code of 1986, as amended (“Section 1446(f)
Withholding Tax”) is not applicable to transfers by non-US unitholders (“Unitholders”) because KORE is a
publicly traded partnership that has, and intends to continue to operate in a manner that will not cause it to
be treated as engaged in a US trade or business.
As set out in the Announcement, the Manager had informed that it had posted a draft qualified notice
(“Qualified Notice”) and will post a final version of the Qualified Notice on 1 January 2023, which is the date
on which the Final Regulations and Section 1446(f) Withholding Tax become effective. In this regard, the
Manager wishes to inform Unitholders that the final Qualified Notice has been posted on its website at
(https://www.koreusreit.com/investor-relations/taxation-information/) and made available together with this
announcement. The final Qualified Notice certifies that KORE was not engaged in a trade or business within
the United States at any time during its taxable year through the “PTP designated date” within the
meaning of the Final Regulations. The final Qualified Notice will be valid for a 92 day period from 1
January 2023 and the Manager intends to issue a new Qualified Notice on a quarterly basis.
Accordingly, and to reiterate, the Section 1446(f) Withholding Tax is not applicable to transfers by
Unitholders. Additionally, brokers that effect a transfer of units in KORE are also not required to withhold
the Section 1446(f) Withholding Tax. Unitholders should not be required to file a US federal income tax
return or apply for a US tax identification number solely as a result of the Section 1446(f) Withholding Tax.
Important Notice
This announcement is for information purposes only and does not constitute or form part of an offer, invitation or
solicitation of any offer to purchase or subscribe for any units in Keppel Pacific Oak US REIT (“Units”).
The value of Units and the income derived from them may fall as well as rise. Units are not obligations of, deposits
in, or guaranteed by, the Manager or any of its affiliates. An investment in Units is subject to investment risks,
including the possible loss of the principal amount invested. Investors have no right to request the Manager to
redeem their Units while the Units are listed. It is intended that Unitholders may only deal in their Units through
trading on Singapore Exchange Securities Trading Limited (the “SGX-ST”). Listing of the Units on the SGX-ST
does not guarantee a liquid market for the Units. The past performance of Keppel Pacific Oak US REIT is not
necessarily indicative of the future performance of Keppel Pacific Oak US REIT.
Source link:https://www.kepcorp.com/
