A Comparison of Selected Features of Real Estate Investment Trust Regimes in the United States, the United Kingdom and Germany

This is the last in a series of four articles, in which the authors compare specific aspects of the real estate investment trust (REIT) regimes in the United States, the United Kingdom and Germany. Previous articles dealt separately with the REIT regimes in each of these countries. The United States has had a REIT regime since the 1960s and was, in many respects, a model for the UK and German regimes. However, both of the new regimes diverged from the US example in a number of ways. This article considers the differences in national circumstances that might have led to the three countries enacting different REIT models. The article also evaluates the advantages and disadvantages of certain features of each regime, and speculates about the future of REITs