Mark Kirshenbaum

Mark Kirshenbaum

Goodwin

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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

1/29/2016 - FIRPTA Income Taxes Pension Funds Protecting Americans from Tax Hikes (PATH) Act REIT Tax Returns Withholding Tax

Partnership Audit and Tax Collection Rules Undergo Fundamental Change

Under the default rule, any adjustment to partnership items or allocations among the partners will be determined, and any tax (including interest and penalties) attributable to adjustments will be collected, at the...more

11/9/2015 - Audits IRS Partnership Agreements Partnerships Pass-Through Entities

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

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

Chairman Camp’s Tax Proposals Would Affect REITs and Real Estate

Chairman David Camp (R-MI) of the U.S. House Ways and Means Committee recently issued a discussion draft of a comprehensive tax reform proposal which would materially modify the taxation of REITs and real estate related...more

3/7/2014 - Corporate Taxes Mortgage REITS Mortgages Property Tax Real Estate Market REIT Tax Reform Ways and Means Committee

Proposed Treasury Regulations Could Significantly Impact Tax Deferral in Partnership Transactions

Late last month, the Treasury Department issued proposed regulations that address partnership liabilities (section 752) and disguised sales of property (Internal Revenue Code section 707). If enacted, the section 752...more

2/4/2014 - IRS Partnerships Tax Deferral U.S. Treasury

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