Two sets of recently finalized regulations provide guidance for REITs.
Key Points:
- Final FIRPTA regulations provide rules for determining whether a REIT is domestically controlled, including a look-through rule for...more
REIT management and boards of directors should review their defensive profile and consider whether to prepare a rights plan.
Key Points:
..Unprecedented market volatility and investor uncertainty due to the coronavirus...more
Recent IRS guidance reduces the minimum aggregate amount of cash required for certain distributions of stock and cash to qualify for the dividends paid deduction.
In order to enhance liquidity of publicly offered real...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects.
On November 26, 2018, the Treasury and...more
12/20/2018
/ C-Corporation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
GILTI tax ,
Interest Payments ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
U.S. Treasury
Recent guidance from Treasury clarifies fundamental aspects regarding the investment of deferred capital gains in QOFs.
Key Points:
..Investors in qualified opportunity funds may derive significant tax benefits in the...more
11/7/2018
/ Capital Gains ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Tax Deferral ,
U.S. Treasury
Appendix at pages 34-43 includes a series of transactional diagrams outlining the main structuring issues in the international context.
Key Points:
..The legislation alters fundamental aspects of US business taxation...more
1/11/2018
/ Corporate Taxes ,
Energy Sector ,
Mortgage REITS ,
Multinationals ,
Net Operating Losses ,
Private Investment Funds ,
Repatriation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
Potential legislation would significantly affect businesses across a variety of sectors.
Key Points:
..US House and Senate have each passed comprehensive tax reform legislation.
..Proposals would alter fundamental...more
Revenue procedure sets forth requirements for ensuring certain stock distributions are treated as property distributions eligible for dividends paid deduction.
On August 11, 2017, the Internal Revenue Service (IRS)...more
Final regulations establish analytical framework for determining whether assets qualify as real property for purposes of the REIT rules.
On August 31, 2016, the Treasury Department and the Internal Revenue Service (IRS)...more
Changes include restrictions on tax-free REIT spinoffs and other reforms generally favorable to REITs and non-US investors in US real estate.
On December 18, 2015, President Obama signed into law the Protecting Americans...more
On September 12, 2012, the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) which make it easier to issue fungible tack-on debt instruments in situations where either the original debt...more