H. Neal Sandford

H. Neal Sandford

Goodwin Procter LLP

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Latest Publications


IRS Announcements Create Market Uncertainty for REIT Spin-Offs

In issuing IRS Notice 2015-59 and Rev. Proc. 2015-43 last week, the IRS intentionally created significant market uncertainty about the viability of “PropCo/OpCo” spin-offs as part of the PropCo’s REIT conversion (e.g., where...more

9/24/2015 - Board of Directors Internal Revenue Code IRS Private Letter Rulings REIT Section 355 Spinoffs Subsidiaries Tax Exemptions

New Proposed Treasury Regulations Focus on Management Fee Waivers

On July 22, 2015, the U.S. Treasury Department and Internal Revenue Service released proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code relating to disguised payments for services between partners...more

7/30/2015 - Clawbacks Compensation Agreements Fee Waivers Fund Sponsors Internal Revenue Code IRS Management Fees Partnership Agreements Partnerships Profits Profits Interests Safe Harbors Significant Entrepreneurial Risk (SER) U.S. Treasury

Chairman Camp’s Tax Proposals Would Affect REITs and Real Estate

Chairman David Camp (R-MI) of the U.S. House Ways and Means Committee recently issued a discussion draft of a comprehensive tax reform proposal which would materially modify the taxation of REITs and real estate related...more

3/7/2014 - Corporate Taxes Mortgage REITS Mortgages Property Tax Real Estate Market REIT Tax Reform Ways and Means Committee

Proposed Treasury Regulations Could Significantly Impact Tax Deferral in Partnership Transactions

Late last month, the Treasury Department issued proposed regulations that address partnership liabilities (section 752) and disguised sales of property (Internal Revenue Code section 707). If enacted, the section 752...more

2/4/2014 - IRS Partnerships Tax Deferral U.S. Treasury

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