Introduction and Background -
Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more
8/17/2020
/ Capital Gains ,
Carried Interest ,
Economic Substance Doctrine ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
Section 385 Proposed Regulations — Impact on Related-Party Financing -
Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more
12/13/2016
/ Audits ,
Bifurcation ,
Change of Ownership ,
Debt ,
Debt Instruments ,
Device Test ,
Equity ,
Expanded Group Instruments (EGIs) ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Operating Losses ,
Partnerships ,
REIT ,
Revenue Procedure 2016-40 ,
Safe Harbors ,
Section 355 ,
Section 385 ,
Stocks ,
Tax-Free Spin-Offs