Michael Brody

Michael Brody

Latham & Watkins LLP

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Latest Publications


Partnerships: IRS Extends Prohibition on Treating Partners as Employees

Employees of partnerships, LLCs or their disregarded entity subsidiaries who receive equity in such entities may be treated as “self-employed” for tax purposes. On May 3, 2016, the US Treasury Department (Treasury)...more

5/13/2016 - Comment Period Disregarded Entities Employee Benefits Employment Tax Income Taxes IRS Limited Liability Companies Proposed Regulation Self-Employment Tax U.S. Treasury

Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions. On April 4, 2016, the US Department of the Treasury (Treasury) and...more

4/21/2016 - Acquisitions Anti-Inversion Regulations Controlled Foreign Corporations Controlled Groups Corporate Taxes De Minimus Quantity Exemption Dividends Foreign Corporations Inversion IRS Multinationals Proposed Regulation Related Parties Stocks U.S. Treasury

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

4/21/2016 - Affiliates Anti-Avoidance Consolidated Tax Returns Controlled Groups Cross-Border Transactions Debt Dividends Foreign Corporations Income Taxes IRS Proposed Regulation REIT Related Parties Required Documentation Stocks U.S. Treasury Withholding Tax

Congress Enacts Significant Changes to the REIT and FIRPTA Rules

Changes include restrictions on tax-free REIT spinoffs and other reforms generally favorable to REITs and non-US investors in US real estate. On December 18, 2015, President Obama signed into law the Protecting Americans...more

12/28/2015 - Capital Gains FIRPTA Protecting Americans from Tax Hikes (PATH) Act REIT

IRS Proposes Guidance on Real Property Definition for REIT Purposes

Proposed regulations establish analytical framework for determining whether assets qualify as real property for purposes of the REIT rules. On May 14, 2014, the Internal Revenue Service (IRS) published in the Federal...more

5/19/2014 - IRS Proposed Legislation Real Estate Investments REIT

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