Jonathan Talansky

Jonathan Talansky

Mintz Levin

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IRS Affirms Treatment of Short Sales for UBTI Purposes

Since there are many hedge funds that utilize short selling as part of their investment strategy, it is important for hedge fund investors, including tax exempt organizations, to understand the U.S. tax treatment of these...more

9/15/2014 - Hedge Funds IRS Private Letter Rulings Short Sales Tax Exempt Entities UBTI

IRS Chief Counsel Shrugs Off Taxpayer’s Section 956 Gambit

In a recently released Chief Counsel Advice Memorandum (the “Memorandum”), the IRS Office of Chief Counsel (International) addressed an interesting and somewhat creative internal financing structure deployed by a taxpayer...more

5/29/2014 - CFC Commercial Loans Corporate Taxes Dividends Financing Insider Loans Inversion IRS Jurisdiction Section 956 Shareholders Subpart F Tax Deferral

Proposed Rules Would Offer REIT Status to Certain Solar Assets

The modified “flow-through” tax treatment afforded to REITs depends on the entity’s ability to meet certain asset and income-based tests, all of which in turn key off of the definition of “real estate.” ...more

5/16/2014 - IRS Property Tax Real Estate Market REIT Renewable Energy Solar Energy

IRS Hits the “Pause” Button on PTP Rulings

Recently it has become standard operating procedure for the Internal Revenue Service (“IRS”) to declare moratoriums on the issuance of private letter rulings (“PLR”) in certain areas. These temporary (or, in certain cases,...more

4/11/2014 - IRS Private Letter Rulings REIT Securities

Final Regulations Illustrate That Lock-Up Arrangements Do Not Prevent Current Taxation Under Section 83

A transfer restriction on its own is not sufficient to defer tax on a compensatory equity grant. This proposition is highlighted by final regulations issued by the IRS on Feb. 25th under Internal Revenue Code section 83. The...more

3/3/2014 - Forfeiture IRC Section 83(b) IRS Lock-Up Agreement Tax Deferral

Tax Court Provides Color on “For Cause” Termination Under Code Section 83

On December 16, 2013, the Tax Court decided a case that sheds important light on the meaning of the term “substantial risk of forfeiture” under section 83 of the Internal Revenue Code of 1986, as amended (the “Code”). The...more

1/31/2014 - ESOP Forfeiture Internal Revenue Code IRS Tax Court Termination Termination Clauses Vesting

The First Circuit’s Sun Capital Decision: Much Ado About Nothing?

The First Circuit’s much-discussed decision in Sun Capital Partners III, LP, et al. v. New England Teamsters & Trucking Industry Pension Fund et al., No. 12-2312 (1st Cir. 2013) has forced many practitioners and commentators...more

12/4/2013 - ERISA Income Taxes Pensions Sun Capital Partners Tax Liability Tax Reform Trucking Industry

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