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
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
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