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
5/10/2024
/ C-Corporation ,
Domestic Corporations ,
Final Rules ,
FIRPTA ,
Foreign Ownership ,
Internal Revenue Code (IRC) ,
Investment Companies ,
IRS ,
Real Estate Investments ,
REIT ,
U.S. Treasury
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
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
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
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
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
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
7/30/2015
/ Clawbacks ,
Compensation Agreements ,
Fee Waivers ,
Fund Sponsors ,
Internal Revenue Code (IRC) ,
IRS ,
Management Fees ,
Partnership Agreements ,
Partnerships ,
Profits ,
Profits Interests ,
Safe Harbors ,
Significant Entrepreneurial Risk (SER) ,
U.S. Treasury
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