Bruce Wein

Bruce Wein

DLA Piper

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IRS Proposed Tax Regulations Aimed at Fee Waiver Arrangements

The Treasury Department and the Internal Revenue Service have issued proposed regulations addressing disguised payment for services of a partner, including the proper tax treatment of fee waiver arrangements commonly used by...more

7/31/2015 - Fee Waivers Fund Managers Investment Funds IRS Partnerships Private Equity Private Equity Funds Profits Interests Safe Harbors Section 409A Section 457A U.S. Treasury

IRS private letter ruling on non-conventional real estate assets enables taxpayer to convert to REIT: key points

The Internal Revenue Service recently released a private letter ruling regarding the treatment of certain assets as qualifying “real estate” for real estate investment trust (REIT) purposes. That ruling effectively enabled...more

1/31/2015 - CFC Corporate Conversions Depreciation GAAP IRS PFIC Popular Private Letter Rulings Real Estate Investments REIT

District court finds that insurance premium excise tax does not apply to retrocession transactions

On February 5, 2014, the US District Court for the District of Columbia held that the federal excise tax ("the FET") on insurance and reinsurance premiums does not apply to retrocession insurance transactions. Under a plain...more

2/7/2014 - Casualty Insurance Excise Tax Federal Taxes Indemnity Insurance Reinsurance Retrocessional Claims

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