Keppel Pacific Oak US REIT *Official* (SGX:CMOU)

[kehyi4]

tsk... BT reported the wrong currency. It's US$0.88

KEPPEL-KBS US REIT Prospectus lodged at MAS OPERA

 

[Jupiter2017]

tsk... BT reported the wrong currency. It's US$0.88

KEPPEL-KBS US REIT Prospectus lodged at MAS OPERA

I noticed they have corrected it online. I have edited my posting too.

 

[MyInvestmentMachine]

US$0.88.... what is the SG$ amount conversion any one knows?

 

[1dollar]

based on the exchange rate of US$1.00 to S$1.3592

US$0.88.... what is the SG$ amount conversion any one knows?

 

[Opps-gal]

based on the exchange rate of US$1.00 to S$1.3592

There should be a given rate for exchange rate. Manulife ipo has also. Still no sign of it... Could be today giving the exchange rate?

 

[anfielder]

There should be a given rate for exchange rate. Manulife ipo has also. Still no sign of it... Could be today giving the exchange rate?

the rate of USD$1 to SGD$1.3592 is mentioned in the prospectus, like 1dollar pointed out.

 

[chowck]

So if we apply via ATM, they shd fix the rate & if not successful or partially successful, they shd refund the excess at the same fixed rate - is this correct?

Otherwise, no one would dare to apply alot if rate keep changing.

 

[anfielder]

So if we apply via ATM, they shd fix the rate & if not successful or partially successful, they shd refund the excess at the same fixed rate - is this correct?

Otherwise, no one would dare to apply alot if rate keep changing.

ya, refund will be at the same rate.

 

[1dollar]

So if we apply via ATM, they shd fix the rate & if not successful or partially successful, they shd refund the excess at the same fixed rate - is this correct?

Otherwise, no one would dare to apply alot if rate keep changing.

Yes, correct. Is fixed at the rate as mentioned below

 

[1dollar]

How many lots you all applying?

 

[Asphodeli]

no hardcopy prospectus at the raffles place booth...

 

[Jupiter2017]

from Kepcorp website:
http://www.kepcorp.com/en/news_item.aspx?sid=7373
…………
………..
THE OFFERING
262,772,400 Units are being offered (the "Offering"), subject to an Over-Allotment Option, at the Offering Price of US$0.88 per Unit.
The Public Offer will open at 8.00 p.m. on Thursday, 2 November 2017, and close at 12 noon on Tuesday, 7 November 2017. Units in Keppel-KBS US REIT are expected to commence trading on the SGX-ST at 2.00 pm on Thursday, 9 November 2017.
Copies of the Prospectus and the application forms relating to the IPO in Singapore of the Units in Keppel-KBS US REIT may be obtained, subject to availability, during office hours from:
- Keppel-KBS US REIT's booth at Ocean Financial Centre (10 Collyer Quay, Singapore 049315), from 3 to 7 November 201715; and
- Branches of DBS Bank Ltd., Citigroup Global Markets Singapore Pte. Ltd., Credit Suisse (Singapore) Limited and Merrill Lynch (Singapore) Pte. Ltd.
The Prospectus is also available on the MAS' OPERA website at https://eservices.mas.gov.sg/opera/. Anyone wishing to acquire the Units will need to make an application in the manner set out in the Prospectus.
..........
..........

 

[asiafrenz]

can use CPF buy or not?

 

[Opps-gal]

http://www.straitstimes.com/business/companies-markets/keppel-kbs-us-reit-has-ambitious-buying-plans

"Close to 70 per cent is Class A."

Good?

 

[Opps-gal]

the rate of USD$1 to SGD$1.3592 is mentioned in the prospectus, like 1dollar pointed out.

Exchange rate better than that Manulife IPO launched last time.

 

[Opps-gal]

can use CPF buy or not?

Not even sure is it on atm, anybody try apply this ipo?

 

[foolosophy]

It’s available on ibanking under invest S$1.20 per share, believe can use atm to subscribe.

 

[stjoe1]

Are the dividends projected taxed by USA?

Anyone managed to get the info on this important piece? How will be the dividend be taxed by US or SG IRAS?

If I recalled correctly Manulife REITS dividend is not taxed by US and SG IRAS as they have some structures.. Sub 1 SG or something..

 

[Opps-gal]

Anyone managed to get the info on this important piece? How will be the dividend be taxed by US or SG IRAS?

If I recalled correctly Manulife REITS dividend is not taxed by US and SG IRAS as they have some structures.. Sub 1 SG or something..

https://eservices.mas.gov.sg/opera/....aspx?prosID=51f5505801bb45e7abc3fb1378372f18


US Federal Income Taxation of Distributions from Parent US REIT To Singapore Sub 1
A distribution by the Parent US REIT to Singapore Sub 1 (which has filed an election to confirm
its classification as a corporation for US federal income tax purposes) that is not attributable to
gain from the sale or exchange of a United States real property interest and that is not designated
as a capital gain dividend, including a deemed distribution such as a consent dividend, will be
treated as an ordinary income dividend to the extent that it is made out of current or accumulated
earnings and profits. A distribution of this type will generally be subject to US federal income tax
and withholding at a rate of 30%. Because the Parent US REIT cannot determine its current and
accumulated earnings and profits until the end of its taxable year, withholding at the rate of 30%
will generally be imposed on the gross amount of any distribution to Singapore Sub 1 that the
Parent US REIT makes and does not designate as a capital gain dividend. Notwithstanding this
withholding on distributions in excess of Parent US REIT’s current and accumulated earnings and
profits, these distributions are a non-taxable return of capital to the extent that they do not exceed
Singapore Sub 1’s adjusted basis in its Parent US REIT units, and the non-taxable return of capital
will reduce the adjusted basis in those units. Singapore Sub 1 may seek a refund from the IRS of
amounts withheld on distributions to it in excess of the Parent US REIT’s current and accumulated
earnings and profits, provided that the applicable withholding agent has properly deposited the
withheld tax with the IRS.
For any year in which the Parent US REIT qualifies as a US REIT, distributions that are attributable
to gain from the sale or exchange of a United States real property interest will be taxed to
Singapore Sub 1 as if these distributions were gains effectively connected with a trade or business
in the United States conducted by Singapore Sub 1. Accordingly, Singapore Sub 1 (i) will be taxed
on these amounts at the normal capital gain and other tax rates applicable to a US corporation,
subject to any applicable alternative minimum tax, (ii) will be required to file a US federal income
tax return reporting these amounts, even if applicable withholding is imposed as described below,
and (iii) it may owe the 30% branch profits tax under Section 884 of the IRC in respect of these
amounts. The 30% branch profits tax will not apply to distributions of proceeds from the sale of the
stock of a Sub-US REIT by Parent US REIT. The Parent US REIT will be required to withhold tax
from distributions to Singapore Sub 1, and remit to the IRS, 35% of the maximum amount of any
such distribution that could be designated as a capital gain dividend. The amount of any tax
withheld will be creditable against Singapore Sub 1’s US federal income tax liability, and
Singapore Sub 1 may file for a refund from the IRS of any amount of withheld tax in excess of that
tax liability, provided that the applicable withholding agent has properly deposited the withheld tax
with the IRS.
Distributions by Keppel-KBS US REIT to a Non-US Unitholder attributable to distributions received
from Singapore Sub 1 will not be subject to US federal income taxation unless (i) the Non-US
Unitholder’s investment in the Units is effectively connected with its conduct of a trade or business
in the United States (and, if provided by an applicable income tax treaty, is attributable to a
permanent establishment or fixed base the Non-US Unitholder maintains in the United States) or
(ii) the Non-US Unitholder is subject to US federal income tax pursuant to the provisions of the US
tax law applicable to US expatriates.
US Federal Income Taxation of Interest Payments from the Parent US REIT to Singapore
Sub 2
Considerations Affecting Unitholders
Singapore Sub 2 will be disregarded as separate from Keppel-KBS US REIT for US federal income
tax purposes pursuant to an entity classification election filed with the IRS. Interest payments to
Singapore Sub 2 will therefore be treated as being received by Keppel-KBS US REIT. As
discussed below, Keppel-KBS US REIT will be treated as a partnership for US federal income tax
purpose. As such, for US federal income tax purposes, each Unitholder will be required to take
into account for US federal income tax purposes its allocable share of interest payments from the
Parent US REIT.
Interest payments from the Parent US REIT to Singapore Sub 2 attributable to the loan from
Singapore Sub 2 will not be subject to US federal income tax or the 30% withholding requirement
to the extent the interest qualifies as “portfolio interest.” The interest will qualify as portfolio
interest with respect to any Non-US Unitholder provided that (i) the beneficial owner does not
actually or constructively own 10% or more of the total combined voting power of all classes of
Units entitled to vote, (ii) the beneficial owner is not a controlled foreign corporation to which
Parent US REIT is a “related person” within the meaning of the IRC, (iii) the beneficial owner has
provided a statement signed under penalties of perjury that includes its name and address and
certifies that it is a Non-US Unitholder in compliance with applicable requirements, on an
applicable IRS Form W-8. In addition to providing an IRS Form W-8, to avoid withholding on its
share of interest payments, each Unitholder must provide Keppel-KBS US REIT with the signed
certifications in Appendix I.

Not sure how attach image with the http thing. so copy paste. At page 321 -322.

 

[Opps-gal]

I think need fill Form W-8 again, like Manulife ipo, to exempt tax?