On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892...more
Per recent transitional guidance, the IRS will not require taxpayers to report transactions involving receipt of digital assets under Section 6050I....more
The Internal Revenue Service (IRS) recently released proposed regulations regarding broker reporting for digital assets, including expansions of and additions to certain definitions, rules, and requirements. The IRS seeks...more
The Internal Revenue Service (IRS) recently ruled that if a taxpayer using a cash method of accounting stakes certain cryptocurrency and receives additional units of such cryptocurrency as rewards for staking, the taxpayer...more
The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. Final regulations under Section 897 regarding the exemption...more
The IRS has effectively delayed the implementation of the new digital asset broker rules under Internal Revenue Code Sections 6045 and 6045A.
The US Treasury Department (Treasury) and Internal Revenue Service (IRS) recently...more
The Internal Revenue Service (IRS) issued Notice 2021-10 on January 19, which extends relief to Qualified Opportunity Funds (QOFs) and their investors as a response to continued challenges brought on by the COVID-19 pandemic....more
1/25/2021
/ Capital Gains ,
Community Development ,
Coronavirus/COVID-19 ,
Economic Development ,
Financial Services Industry ,
Infectious Diseases ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Planning
With the issuance of Notice 2020-39 (the Notice), the Internal Revenue Service (IRS) has provided relief for Qualified Opportunity Zone Funds (QOFs) and for investors in QOFs. While the relief provided in the Notice does not...more
6/24/2020
/ Community Development ,
Construction Project ,
Economic Development ,
Investment ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Popular ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Relief Measures ,
Tax Planning ,
Urban Planning & Development
New guidance from the Internal Revenue Service will allows RICs and REITs to retain more capital by distributing less cash to shareholders in certain stock distributions—welcome relief during the current economic volatility...more
The Internal Revenue Service on Monday, April 13 issued welcome relief to the securitization industry, providing that certain forbearances and related modifications to mortgages will generally not cause real estate mortgage...more
The US Internal Revenue Service (IRS) issued proposed regulations on May 7 that would expand tax withholding and reporting requirements in certain sales or exchanges of interests in partnerships engaged in one or more US...more
The Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) issued the much-anticipated second set of proposed regulations (the Proposed Regulations) on April 17 regarding Qualified Opportunity Zone...more
In a big win for the industry, final regulations issued by the Internal Revenue Service and US Department of Treasury do not adopt all the rules set forth in the proposed regulations. Instead, regulated investment companies...more
The US Department of the Treasury and the Internal Revenue Service (IRS) released much-anticipated guidance on October 19 on investments in the new Opportunity Zone Funds. The release included proposed regulations...more
The US Department of the Treasury and the Internal Revenue Service on April 2 issued “Initial Guidance Under Section 163(j) as Applicable to Taxable Years Beginning After December 31, 2017” (Notice 2018-28), which announces...more
In a recently released memorandum, the Internal Revenue Service suggests an expansion of those risks qualifying for the favorable tax treatment accorded insurance risks....more
The IRS has issued Revenue Procedure 2017-45, which provides that certain distributions of stock by a publicly offered RIC or publicly offered REIT made pursuant to a “cash or stock election” will be treated as a taxable...more
Sponsoring entities should evaluate which of their sponsored entities should be registered via the IRS registration portal....more
The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more
Fines pertaining to violations of federal securities laws and certain FINRA rules may not be deducted.
The Internal Revenue Service (IRS) in low-level advice recently announced its position that certain fines paid to...more
The regulations affect both real estate investment trusts (REITs) and regulated investment companies (RICs) that receive appreciated property from a C corporation in a so-called “conversion transaction.”...more
The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more
5/24/2016
/ Diversification Requirements ,
Floating NAV ,
Income Taxes ,
Insurance Industry ,
Internal Revenue Code (IRC) ,
IRS ,
MMF ,
Money Market Funds ,
Registered Investment Companies (RICs) ,
RICs ,
Securities and Exchange Commission (SEC)
IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more
The Treasury and the IRS have delayed implementation of the recently announced rule change that treats certain types of upfront payments on swaps as loans for federal income tax purposes (including for purposes of the...more
10/15/2015
/ Comment Period ,
Debt Financing ,
Dodd-Frank ,
Exceptions ,
Income Taxes ,
IRS ,
Loans ,
Proposed Regulation ,
SIFMA ,
Swaps ,
Tax Exempt Entities ,
U.S. Treasury
Certain individuals who have only signature authority over foreign financial accounts now have until June 30, 2016 to file the Report of Foreign Bank and Financial Accounts....more