ILG and Starwood Provide FIRPTA Update on Vistana Acquisition

Interval Leisure Group and Starwood Hotels & Resorts have concluded that no withholding of tax under the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) is required with respect to ILG common stock received by any person in ILG’s upcoming acquisition of Starwood’s vacation ownership business, Vistana Signature Experiences.

In addition, the parties are working with the Internal Revenue Service to confirm that any gain realized by a non-U.S. holder that is treated for tax purposes as owning 5% or less of the stock of Starwood and Vistana between and including the record date and the closing date will not be subject to FIRPTA tax on the disposition of Vistana stock in the transaction.

Shareholders should consult their tax advisors as to the particular tax consequences to them of the transactions.

The acquisition, which will occur through a merger of a wholly-owned subsidiary of ILG with and into Vistana following the spin-off of Vistana from Starwood, is expected to close by the end of this week, subject to satisfaction or waiver of customary closing conditions. 

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