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Recent U.S. Tax Court Case Reverses Long Held IRS Position Regarding Taxation of Sales of Partnership Interests by Foreign...

Following the inauguration of the new administration in January 2017, many investors were anticipating the passage of a transformative tax reform bill at some point in 2017. Although legislative tax reform is seemingly...more

The White House’s Regulatory “Freeze” Includes Tax Regulations

On January 20, 2017, White House Chief of Staff Reince Priebus issued a Memorandum for the Heads of Executive Departments and Agencies (the “Freeze Order”) that ordered agencies to (i) refrain from sending regulations to the...more

The U.S. Treasury Releases New FIRPTA Regulations

On February 17, 2016, the U.S. Treasury released new regulations (the New FIRPTA Regulations) that reflect changes that the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) made to the Foreign Investment in Real...more

Tax Code Amendments Facilitate Foreign Investment in REITs and U.S. Commercial Properties; Increase FIRPTA Withholding Tax Rate

On December 18, 2015, the United States Congress enacted the Protecting Americans from Tax Hikes Act of 2015 (the Act). Among other things, the Act permanently extends many “popular” tax provisions (e.g., the research and...more

Locke Lord QuickStudy: Tax Code Amendments Proposed to Facilitate Foreign Investment in REITs and U.S. Commercial Properties

On April 30, 2015, Representatives Kevin Brady (R-TX) and Joe Crowley (D-NY), both members of the U.S. House Ways & Means Committee, introduced legislation intended to encourage foreign investment in United States real...more

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