On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships:
In new proposed regulations, the IRS identified several...more
On October 9, 2019, the Internal Revenue Service (IRS) issued long-awaited guidance relating to transactions involving virtual currencies, such as cryptocurrencies. Aligned with the agency’s continuing efforts to enforce tax...more
10/18/2019
/ Bitcoin ,
Capital Gains ,
Capital Losses ,
Charitable Donations ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
Fair Market Value ,
Gifts ,
Information Reports ,
IRS ,
New Guidance ,
Recordkeeping Requirements ,
Revenue Rulings ,
Self-Employment Tax ,
Taxable Income ,
Virtual Currency
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
On April 4, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would become retroactively effective to April 4, 2016, and dramatically alter the tax...more
New Regulations Address Some Concerns and Coordinate FATCA Rules with Other Reporting and Withholding Rules -
On February 20, 2014, the Department of the Treasury and the IRS issued a comprehensive set of final and...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 January 29, 2014, the Internal Revenue Service (the IRS) and the Treasury Department (Treasury) introduced a long-awaited package of proposed regulations (the Proposed Regulations) that would significantly change the rules...more
As part of 2010 legislation, Congress enacted section 871(m) of the Internal Revenue Code, which provides that payments made to foreign persons under specified notional principal contracts (“Specified NPCs”), securities...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
On October 29, 2013, the IRS issued Notice 2013-69 as the next step in implementing far-reaching legislation commonly known as the Foreign Account Tax Compliance Act (FATCA).
Congress enacted FATCA in 2010 as part 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
On January 17, 2013, the Treasury Department and the IRS issued comprehensive final regulations implementing Sections 1471 through 1474 of the Internal Revenue Code (commonly known as the Foreign Account Tax Compliance Act,...more