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
10/26/2016
/ Capital Expenditures ,
Debt ,
Debt Financing ,
Disguised Sales ,
Final Rules ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
Reporting Requirements ,
Risk Allocation ,
Tax Structuring ,
U.S. Treasury
President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired...more