Dear Clients and Friends:
On March 27, 2026, a Decree was published in the Federal Official Gazette (“DOF”) amending, adding, and repealing various provisions contained in the Regulations of the Federal Law for the Prevention and Identification of Transactions with Illicit Proceeds (“Anti-Money Laundering Law”). This reform includes changes that may impact on the real estate development industry and may increase the level of compliance of the companies.
Among the main changes, the inclusion of trusts and any other legal vehicles that carry out vulnerable activities stands out, as they are now required to register with the Federal Taxpayers Registry (“RFC”) and obtain their e-signature (formerly known as “FIEL”), which may have relevant implications for the structuring of real estate developments.
In our experience, it is common for real estate projects with certain features to be structured through the incorporation of a trust as the main vehicle to carry out the development, operation, and commercialization of the project jointly with other legal vehicles, taking into consideration the strategic allocation of functions, assets, and risks to optimize and manage the corresponding tax impact.
Our recommendation is to evaluate on a case-by-case basis how your real estate projects are structured, to identify potential solutions and thus mitigate tax, real estate, and/or Anti-Money Laundering contingencies.
At EC Rubio, we have a highly specialized team dedicated to tax and real estate consulting focused on real estate development projects, and we remain at your disposal to assist you with your project.
Should you have any questions or comments regarding the foregoing, please do not hesitate to call your usual contact in the Firm.
Tax and Real Estate
Juan S. Vázquez / juan.vazquez@ecrubio.com
David Bermúdez / david.bermudez@ecrubio.com
Arturo J. Bañuelos / arturo.banuelos@ecrubio.com
Alejandro Montes / alejandro.montes@ecrubio.com
Carlos Enríquez / carlos.enriquez@ecrubio.com
César Ochoa / cesar.ochoa@ecrubio.com
Daniela Flores / daniela.flores@ecrubio.com
David Ken Fujii / david.fujii@ecrubio.com
Eduardo David / eduardo.david@ecrubio.com
Edmundo Hernández / edmundo.hernandez@ecrubio.com
Felipe Mendoza / felipe.mendoza@ecrubio.com
Fernando Holguín / fernando.holguin@ecrubio.com
Javier Ogarrio / javier.ogarrio@ecrubio.com
Jaime O’Reilly Pérez / jaime.oreilly@ecrubio.com
Renato Martínez / renato.martinez@ecrubio.com
René Mauricio Alva / rene.alva@ecrubio.com
Sergio De La Rocha / sergio.delarocha@ecrubio.com
Franco Herrera / franco.herrera@ecrubio.com
Gloria Domínguez / gloria.dominguez@ecrubio.com
Andrea Santoy / andrea.santoy@ecrubio.com
Avilix / avilix.gomez@ecrubio.com
Carlos Canseco / carlos.canseco@ecrubio.com
Fernanda Pompa / fernanda.pompa@ecrubio.com
Jaime Ogushi / jaime.ogushi@ecrubio.com
Luis Delgado / luis.delgado@ecrubio.com
Marcela Villatoro / marcela.villatoro@ecrubio.com
Sofía Ramírez / sofia.ramirez@ecrubio.com