The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently.
What Is (and Is Not) Covered?
The three-year restriction applies with respect to...more
9/1/2020
/ Capital Gains ,
Carried Interest ,
Economic Substance Doctrine ,
Holding Periods ,
Income Taxes ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
New IRS guidance issued on qualified foreign pension fund exception.
On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more
6/13/2019
/ Anti-Abuse Rule ,
FATCA ,
FIRPTA ,
Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
New Guidance ,
Pension Funds ,
Proposed Regulation