Brett Fieldston

Brett Fieldston

Akin Gump Strauss Hauer & Feld LLP

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IRS Internal Memorandum Advises That Self-Employment Tax Applies to Profits From an Investment Manager

On September 5, 2014, the Office of Chief Counsel, Internal Revenue Service (IRS) released an internal generic legal advice memorandum advising an IRS field agent that the statutorily provided “limited partner” exception to...more

9/11/2014 - Income Taxes Investment Adviser IRS Self-Employment Tax

Treasury Proposes REIT Solar Regulations but Excludes Most Common Transactions

On the same day as President Obama’s speech championing solar, the Department of the Treasury proposed regulations defining “real estate assets” for purposes of the definition of a real estate investment trust (REIT). The...more

5/13/2014 - Barack Obama MLPs Partnership Agreements Publicly-Traded Companies Real Estate Investments REIT Solar Panels U.S. Treasury

Treasury Delays Implementation of Final Expanded Dividend-Equivalent Regulations By Two Years, Keeps Current Four-Factor Test in...

The Department of the Treasury and the Internal Revenue Service (IRS) announced today (available here) that they are delaying the implementation by two years—until January 1, 2016—of final expanded regulations governing the...more

12/5/2013 - Corporate Taxes Dividends Foreign Corporations Income Taxes IRS U.S. Treasury

FATCA Implementation Further Delayed Until July 1, 2014, FFIs Should Finalize Registrations by April 25, 2014

The Internal Revenue Service (IRS) issued Notice 2013-43 (available here), which delays by six months certain of the timelines during which withholding agents and foreign financial institutions (FFIs) will be required to...more

7/17/2013 - Delays FATCA FFI Foreign Banks Grandfathering Rules IGAs IRS U.S. Treasury

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