On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA. ...more
On October 19, 2018, the Internal Revenue Service (the “IRS”) and the Treasury Department issued proposed regulations relating to the new Opportunity Zone program....more
10/30/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investment Opportunities ,
IRS ,
Low Income Housing ,
New Market Tax Credits ,
Opportunity Zones ,
Proposed Regulation ,
Public Finance ,
Real Estate Development ,
Real Estate Market ,
Safe Harbors ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury
On December 20, 2017, the Senate and House of Representatives passed H.R. 1, known as the “Tax Cuts and Jobs Act” (“Tax Reform Bill”). President Trump is expected to sign the Tax Reform Bill by early January. The Tax Reform...more
12/21/2017
/ Business Taxes ,
Carried Interest ,
Corporate Taxes ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
Legislative Agendas ,
Like Kind Exchanges ,
Net Operating Losses ,
Pending Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On December 2, 2017, the Senate passed a tax reform bill that differs in some key aspects from the tax reform bill the House approved on November 16, 2017. A House and Senate conference committee will begin work to resolve...more
12/13/2017
/ BEPS ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
Legislative Agendas ,
Like Kind Exchanges ,
Net Operating Losses ,
Popular ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 14, 2017, Senate Finance Committee Chairman, Orrin Hatch (R-Utah), released his modified tax reform plan (“Senate Bill”), which adopts some of the House Bill proposals (as amended) (“House Bill”), but also...more
11/20/2017
/ Carried Interest ,
Corporate Taxes ,
EBITDA ,
Excise Tax ,
Insurance Industry ,
International Tax Issues ,
Legislative Agendas ,
Like Kind Exchanges ,
Net Operating Losses ,
Partnership Interests ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more
11/9/2017
/ Collateralized Loan Obligations ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
Legislative Agendas ,
Legitimate Business Interest ,
Pass-Through Entities ,
Securitization Vehicles ,
Tax Code ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
UBTI
On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”) which includes significant changes to the current U.S. federal income tax regime for businesses and...more
11/6/2017
/ Business Taxes ,
Corporate Counsel ,
Corporate Taxes ,
Excise Tax ,
Insurance Industry ,
International Tax Issues ,
Like Kind Exchanges ,
Net Operating Losses ,
Partnerships ,
Related Parties ,
S-Corporation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On December 2, the U.S. Internal Revenue Service issued Notice 2016-76, which phases in the application of withholding on dividend equivalent payments under section 871(m). Under the notice, withholding applies only to...more
Proposed regulations issued on July 14, 2016 generally would prevent tax-free spinoffs involving companies with less than 5% active business assets and spinoffs where one company holds a substantial amount of nonbusiness...more
On November 19, 2015, Treasury issued Notice 2015-79 (the “Notice”), which announces Treasury’s intent to issue regulations reducing the tax benefits available to inverted groups and making it more difficult for some U.S....more