On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more
5/10/2024
/ C-Corporation ,
Domestic Corporations ,
Final Rules ,
FIRPTA ,
Foreign Ownership ,
Internal Revenue Code (IRC) ,
Investment Companies ,
IRS ,
Real Estate Investments ,
REIT ,
U.S. Treasury
On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more
1/27/2021
/ Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Carried Interest Tax Rates ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Partnership Interests ,
Partnerships ,
Tax Rates ,
U.S. Treasury
The U.S. Treasury Department and the Internal Revenue Service recently released proposed regulations under Section 1061 of the Internal Revenue Code of 1986, as amended.1 Congress enacted Section 1061 in 2017 in order to...more
8/26/2020
/ APIs ,
Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Holding Periods ,
Internal Revenue Code (IRC) ,
IRS ,
Partnership Interests ,
Pass-Through Entities ,
Proposed Regulation ,
Recharacterization ,
U.S. Treasury
The Bipartisan Budget Act of 2015 fundamentally changes the rules and procedures governing IRS audits of partnerships for taxable years beginning on or after January 1, 2018. These new rules are contained in new Sections...more
Under the default rule, any adjustment to partnership items or allocations among the partners will be determined, and any tax (including interest and penalties) attributable to adjustments will be collected, at the...more
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
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 (IRC) ,
IRS ,
Management Fees ,
Partnership Agreements ,
Partnerships ,
Profits ,
Profits Interests ,
Safe Harbors ,
Significant Entrepreneurial Risk (SER) ,
U.S. Treasury
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