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IRS Finalizes Regulations for Domestically Controlled REITs and other Qualified Investment Entities

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

Highlights From The Final Carried Interest Regulations

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

Highlights From The Proposed Carried Interest Regulations

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

What REITs Need to Know About the New Partnership Audit Rules

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

Partnership Audit and Tax Collection Rules Undergo Fundamental Change

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

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

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

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

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