Andrea Macintosh Whiteway

Andrea Macintosh Whiteway

McDermott Will & Emery

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Focus on Tax Strategies & Developments - November 2014

REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more

11/12/2014 - Corporate Taxes FATCA Income Taxes Inversion Mortgages Real Estate Market REIT Spinoffs Subpart F Tax Structuring

Proposed Regulations Clarify Definition of “Real Property” for Real Estate Investment Trusts

On May 9, 2014, the Internal Revenue Service and U.S. Department of the Treasury issued proposed regulations (the Proposed Regulations) under Section 856 of the Internal Revenue Code (the Code) to clarify the definition of...more

5/23/2014 - Business Assets C-Corporation IRS Private Letter Rulings Proposed Regulation Real Estate Investments REIT U.S. Treasury

New Proposed Partnership Liability Allocation Regulations May Trigger Gains for Partners

On January 29, 2014, the U.S. Department of the Treasury and the Internal Revenue Service issued far-reaching and extremely taxpayer-adverse proposed regulations dealing with the allocation of partnership recourse and...more

2/12/2014 - Capital Gains Corporate Taxes Partnerships Recourse Proceedings U.S. Treasury

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