On April 25, 2024, the IRS and Treasury issued final regulations (the “Final Regulations”) addressing whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute a...more
On December 29, 2022, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) addressing (1) whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute...more
On December 27, 2022, the IRS and Treasury issued Notice 2023-2 (the “Notice”), which provides guidance relating to the application of the new excise tax on repurchases of corporate stock (the “Stock Buyback Tax”) under...more
12/30/2022
/ De Minimus Quantity Exemption ,
Fair Market Value ,
Guidance Update ,
Internal Revenue Code (IRC) ,
IRS ,
Minority Shareholders ,
Netting Agreements ,
REIT ,
Share Buybacks ,
Shareholders ,
Special Purpose Acquisition Companies (SPACs) ,
U.S. Treasury ,
Valuation
The recently proposed “Inflation Reduction Act of 2022” includes a proposal (the “carried interest proposal”) to amend the rules under section 1061 of the Internal Revenue Code of 1986, as amended (the “Code”) relating to the...more
Investors and project sponsors await proposed regulations and interim guidance under Section 45Q of the Internal Revenue Code to resolve uncertainty and unlock significant carbon capture, utilization and storage market...more
1/31/2020
/ Carbon Capture and Sequestration ,
Carbon Emissions ,
Energy Projects ,
Energy Sector ,
Greenhouse Gas Emissions ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Qualifying Facility ,
Tax Credits ,
Underground Storage Tanks
On December 19th, 2019, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued regulations (the “Final Regulations”) under Section 1400Z-2 of the Internal Revenue Code (the “Code”)[i] finalizing,...more
12/31/2019
/ Capital Gains ,
Capital Gains Tax ,
Community Development ,
Economic Development ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Popular ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Deferral ,
U.S. Treasury
The Qualified Opportunity Zone rules under Section 1400Z of the Internal Revenue Code permit certain investors to realize substantial tax benefits if they invest capital into federally-designated low-income communities known...more
6/24/2019
/ Capital Gains ,
Community Development ,
Deadlines ,
Electricity ,
Energy Sector ,
Energy Storage ,
Infrastructure Financing ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Opportunities ,
Investment Tax Credits ,
Joint Venture ,
Low Income Housing ,
Opportunity Zones ,
Production Tax Credit ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Renewable Energy ,
Renewable Energy Incentives ,
Safe Harbors ,
Tax Cuts and Jobs Act ,
Tax Deferral
On May 22, 2019 the Treasury Department and the Internal Revenue Service released regulations (the “Final Regulations”) finalizing and making certain technical changes to proposed regulations (the “Proposed Regulations”,...more
5/29/2019
/ Controlled Foreign Corporations ,
Dividends ,
Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Proposed Regulation ,
Section 956 ,
Subsidiaries ,
U.S. Treasury
On October 31, 2018, the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) which likely will facilitate (i) the making of loans by foreign corporate subsidiaries to a U.S. parent...more
On October 19, 2018, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under new section 1400Z-2 of the Internal Revenue Code (the “Code”),...more
On January 23, the Internal Revenue Service (the “IRS”) released Revenue Procedure 2018-12 (the “Revenue Procedure”) detailing a safe harbor that will permit taxpayers to utilize average-price methods for purposes of...more
In Technical Advice Memorandum 2017-29-020 (July 21, 2017) (the “TAM”), the IRS denied claims by two tax equity investors (the “Investors” or each an “Investor”) for renewable energy tax credits on grounds that the...more
Executive Summary On November 22, the Internal Revenue Service (“IRS”) and Treasury Department issued proposed regulations (REG-136978-12, the “Proposed Regulations”) under the “fractions rule” of Section 514(c)(9)(E) of the...more