Laurence Crouch

Laurence Crouch

Shearman & Sterling LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

Proposed Regulations Provide Greater Certainty on the REIT Classification of Solar and Other Non-Traditional Assets

The Internal Revenue Service (the “IRS”) and Treasury Department have proposed regulations (the “Proposed Regulations”) under Section 856 of the Internal Revenue Code providing guidance for analyzing whether non-traditional...more

5/15/2014 - Business Assets IRS Proposed Regulation Real Estate Investments REIT Solar Panels Spinoffs Tax Planning U.S. Treasury

New Temporary Regulations Introduce a Welcome De Minimis Rollover-Shareholder Exception to US Anti Inversion Rules

On January 16, 2014, the Treasury Department and the Internal Revenue Service released new temporary regulations on one aspect of corporate inversions under Section 7874 (the “Regulations”) that altered and clarified the...more

1/22/2014 - Corporate Taxes De Minimis Claims De Minimus Quantity Exemption Exclusions Inversion IRS Shareholders U.S. Treasury

United States Signs FATCA Intergovernmental Agreement With the Cayman Islands

The US Department of the Treasury recently announced that the United States has signed a “Model 1” intergovernmental agreement (an “IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”) with the Cayman...more

12/9/2013 - FATCA IGAs

Revival of REIT Rulings Could Mean Good News for Companies with Non-Traditional Assets Considering Becoming REITs

In recent years, there has been a considerable expansion of the types of companies holding non-traditional real estate assets that have elected to become real estate investment trusts for US federal income tax purposes...more

11/25/2013 - Income Taxes IRS Mortgage REITS Mortgages Real Estate Market REIT

California Reduces Rate of Section 409A State Excise Tax

In a positive development for employees, California recently reduced its excise tax rate for failures to comply with the California analog to Section 409A of the Internal Revenue Code of 1986, as amended (“Section 409A”)....more

10/25/2013 - Excise Tax IRC Section 409A State Taxes

Cayman Islands Government Announces FATCA Intergovernmental Agreement

The Cayman Islands government announced on August 13, 2013 that it has concluded negotiations with the US government on a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act...more

8/22/2013 - Compliance FATCA Intergovernmental Agreements Tax Reform TIEA

Timeline for Initial FATCA Implementation Extended

The Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) announced on July 12, 2013 a general six-month extension to the timeline for initial implementation of the Foreign Account Tax Compliance Act...more

7/16/2013 - Delays FATCA FFI Foreign Banks IGAs IRS U.S. Treasury

Expansion of REIT-able Assets and REIT Conversions

In recent years, the US Internal Revenue Service has considerably expanded the categories of real estate assets that may be owned by a real estate investment trust (a “REIT”). This expansion of qualifying or “REIT-able”...more

5/30/2013 - IRS Pipelines Power Plants Railways REIT Timber Wireless Industry

8 Results
|
View per page
Page: of 1