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Global Tax News - February 2016

The European Commission has released its highly anticipated anti-tax-avoidance package. The package, released January 28, 2016, contains proposed rules and recommendations to avoid aggressive tax planning within the...more

FIRPTA reform under the Protecting Americans from Tax Hikes Act of 2015: key points for non-US investors

Among the reforms and provisions in the Protecting Americans From Tax Hikes Act of 2015 are several important changes to the Foreign Investment in Real Property Tax Act of 1980 (commonly referred to as FIRPTA) that are...more

PATH Act takes taxpayer-friendly approach in amending and clarifying partnership audit and litigation procedures

President Obama has signed into law tax extenders legislation, entitled the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act), which will extend more than 50 expiring provisions of the Internal Revenue Code. ...more

Real Estate Gazette - Issue 22: Focus on Specialized Assets

It is clear that demographics play a part in dictating which investment opportunities are prominent at any point in time. For example, in France, the rise in student numbers has boosted demand for student accommodation in the...more

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

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

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

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