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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

New IRS and FinCEN Reporting Requirements for Businesses that Accept Payments in Digital Assets

Although the Internal Revenue Service (IRS) has postponed broker-related digital asset reporting, a less publicized requirement that applies long-standing reporting rules for physical cash payments to businesses that accept...more

Department of Health and Human Services Recommends that Cannabis be Rescheduled as a Schedule III Drug Under the Controlled...

On October 6, 2022, President Biden pardoned all Federal offenses of simple possession of cannabis. On that same day, Biden directed the Secretary of Health and Human Services and the Attorney General to commence the...more

Current Issues for Qualified Small Business Stock - How New R&E Expensing Rules Could Hurt Your QSBS Status, and Why Cash...

An early-stage company can offer prospective investors an attractive investment opportunity, particularly if the company’s stock will qualify as “qualified small business stock” (QSBS) for US federal income tax purposes. This...more

New Qualified Opportunity Fund Guidance – Significant Forward Progress but Important Questions Remain Unanswered

The Treasury Department and Internal Revenue Service recently issued proposed regulations (the Proposed Regulations) and Revenue Ruling 2018-29 (the QOZ Revenue Ruling), providing much anticipated guidance for Qualified...more

New FIRPTA Changes Provide Significant Opportunities, But No Panacea for Encouraging Non-U.S. Investment in U.S. Real Estate

Under FIRPTA, a non-U.S. person’s gain from the sale of U.S. real property interests is treated as income that is effectively connected with a U.S. trade or business (“ECI”), and therefore, is subject to U.S. federal income...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

Fund Sponsor Entities With San Francisco Activities May See Significant Tax Increases Under Gross Receipts Tax

San Francisco’s gross receipts tax (GRT) began phasing in this year and will be fully implemented in 2018. While the tax rates are lower than those under the previous payroll tax system, the GRT may lead to higher taxes for...more

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