In late September, the IRS issued final regulations describing six requirements for a transaction or series of transactions to qualify as a reorganization under Section 368(a)(1)(F) (an “F reorganization”). The IRS...more
In the recent Rev. Proc. 2015-40, the IRS describes updated competent authority procedures for taxpayers seeking certain U.S. treaty relief. The new procedures, effective for requests on or after October 30, 2015, supersede...more
Like-kind exchanges are well-known events in the field of investment real estate. The tax law has spent about the last 30 years refining the deferred like-kind exchange, in which the taxpayer is given time to locate the...more
9/2/2015
/ Business Assets ,
Capital Gains ,
Commercial Real Estate Market ,
Cross-Border Transactions ,
Foreign Affiliates ,
Goodwill ,
Intangible Property ,
Real Estate Investments ,
Related Parties ,
Section 1031 Exchange ,
Tax Planning
Beginning with foreign bank account reports (FinCEN Form 114, known as the FBAR) for the 2016 calendar year, FBARs will be due on April 15 of the following year. A six-month extension to October 15 will be available upon...more