Seth Eaton Discusses Modifications and Workouts of Commercial Real Estate Loans during the COVID-19 Pandemic
Two sets of recently finalized regulations provide guidance for REITs. Key Points: - Final FIRPTA regulations provide rules for determining whether a REIT is domestically controlled, including a look-through rule for...more
On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more
The U.S Department of the Treasury and the Internal Revenue Service on June 24, 2020 issued final tax regulations ("Final Regulations") that permit a regulated investment company (“RIC”) to report to its shareholders the...more
Comments are due on April 9, 2019 with respect to the recent proposed regulations regarding eligibility of qualified REIT dividends for the qualified business income deduction under Code Section 199A. On January 18, 2019...more
On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more
Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more
On Monday, the IRS released Notice 2015-59. In it, the IRS announced that the IRS will no longer issue private letter rulings on whether a distribution satisfies the requirements of Section 355 for a tax-free spin-off where...more