Many upstream and midstream companies are grappling with the prospect of severe liquidity constraints due to the rapid deterioration of both the commodity markets and the debt capital markets. While upstream companies have...more
3/24/2020
/ Debt Market ,
International Tax Issues ,
Market Pricing ,
Midstream Contracts ,
Oil & Gas ,
Oil Prices ,
REIT ,
Risk Assessment ,
Tax Liability ,
Tax Planning ,
Upstream Contracts
The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more
11/13/2018
/ Asset Valuations ,
C-Corporation ,
Capital Gains ,
Community Development ,
Investment Funds ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
QOZBP ,
Qualified Opportunity Funds ,
Real Estate Investments ,
REIT ,
RICs ,
S-Corporation ,
Startups ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
U.S. Treasury
On August 11, 2017, the Internal Revenue Service released guidance allowing publicly offered real estate investment trusts and regulated investment companies to distribute earnings in a combination of cash and stock as long...more
On October 4, 2016, the Internal Revenue Service and the Treasury Department issued a sweeping package of proposed, temporary and final regulations under the Internal Revenue Code that, among other things, significantly...more
10/10/2016
/ Capital Gains ,
Debt Instruments ,
Disguised Sales ,
Internal Revenue Code (IRC) ,
Joint Venture ,
Master Limited Partnerships ,
Non-Recourse Loans ,
Partnership Liabilities ,
Partnerships ,
Publicly-Traded Companies ,
REIT ,
Tax Allocation Agreements ,
Tax Liability ,
Tax-Deferred Exchanges
The Internal Revenue Service (IRS) and Treasury Department today issued a much-welcomed technical correction to the effective date of the recently issued “built-in gain” regulations regarding real estate investment trust...more
On June 7, 2016, the Internal Revenue Service (IRS) and Treasury Department issued new temporary regulations that have dramatic implications for all merger-and-acquisition activity by C corporations and real estate investment...more
6/9/2016
/ Acquisitions ,
C-Corporation ,
Capital Gains ,
Corporate Taxes ,
IRS ,
Mergers ,
Protecting Americans from Tax Hikes (PATH) Act ,
REIT ,
RICs ,
S-Corporation ,
Tax-Free Spin-Offs
The newly signed Protecting Americans from Tax Hikes Act of 2015 (the Act) includes several reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) and the taxation of real estate investment trusts...more
President Obama signed into law a bill that will significantly reform the taxation of real estate investment trusts (REITs). Most notably, the Protecting Americans from Tax Hikes Act of 2015 (the Bill) prevents companies from...more
On December 18, 2015, President Obama signed into law a bill that will significantly reform the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). The Protecting Americans from Tax Hikes Act of 2015 (the Bill) will...more
This afternoon, Reps. Kevin Brady (R-Texas) and Joseph Crowley (D-N.Y.) re-introduced in the House of Representatives a bill to significantly reform the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R....more
On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more
2/14/2015
/ Capital Gains ,
Corporate Taxes ,
Debt Securities ,
FIRPTA ,
Foreign Investment ,
Investment Portfolios ,
Pension Funds ,
Real Estate Investments ,
Regulatory Reform ,
REIT ,
Senate Finance Committee ,
Tax Liability ,
Tax Treaty
On May 9, 2014, the U.S. Department of the Treasury (Treasury) released proposed regulations defining the term “real property” for purposes of the REIT rules. The proposed regulations, which provide a framework for taxpayers,...more
On February 25, House Ways and Means Committee Chairman David Camp (R. Mich.) proposed a dramatic overhaul of the U.S. tax code (the Code). While the “Tax Reform Act of 2014,” (the Proposals) contains a number of previously...more
On November 14, the IRS contacted many firms to let them know that the so-called REIT working group has completed its task. The IRS’s temporary hold on issuing rulings on what constitutes real property for REIT purposes is...more
Yesterday, Reps. Kevin Brady of Texas and Joseph Crowley of New York proposed a major reform to the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R. 2870, the Real Estate Investment and Jobs Act of...more
A significant amount of press attention has been given to an unusual press release filed with the SEC yesterday by Iron Mountain regarding its planned conversion to a real estate investment trust (REIT). Iron Mountain said...more
Sponsors and investors have been paying much attention to the potential use of real estate investment trust (REIT) structures to hold and finance renewable energy assets in a tax-efficient way. A recent SEC filing by Hannon...more