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Eversheds Sutherland (US) LLP

Treasury and the IRS issue final regulations addressing the payment and reporting of the stock buyback tax

Eversheds Sutherland (US) LLP on

On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more

Vinson & Elkins LLP

Considerations for REITs, their Subsidiaries, and Other Real Estate Companies under the Corporate Transparency Act

Vinson & Elkins LLP on

The Corporate Transparency Act (the “CTA”), a new federal law, went into effect on January 1, 2024. The CTA requires that certain entities file Beneficial Ownership Information Reports (“BOI Reports”) with the Financial...more

Proskauer - Regulatory & Compliance

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

Proskauer - Regulatory & Compliance on

In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

Dechert LLP

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers (UPDATED)

Dechert LLP on

In March 2022, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of U.S. ownership of foreign securities....more

Whitman Legal Solutions, LLC

Corporate Transparency Act–What Real Estate Sponsors and Investors Should Do Now to Prepare

Whitman Legal Solutions, LLC on

Businesses facing a new law or regulation are like orchestra musicians. Most businesses will plan ahead so they can comply with new legal requirements on the law’s effective date. However, some laws are general and...more

Troutman Pepper

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper on

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

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

White & Case LLP on

On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Dechert LLP

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers

Dechert LLP on

TIC SHC is a mandatory benchmark study commissioned by the Treasury and administered by the FRBNY every five years.3 The survey reviews holdings of foreign portfolio securities – including short- and long-term securities and...more

Dechert LLP

New Treasury Regulations Curtail Planning Opportunities for Partnership Structures

Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more

Seyfarth Shaw LLP

There is life after death...of the Bottom-Dollar Guarantee

Seyfarth Shaw LLP on

Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Morrison & Foerster LLP on

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

Morrison & Foerster LLP

Tax Talk -- Volume 7, No. 2 -- July 2014

Morrison & Foerster LLP on

In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more

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