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Treasury Department Issues Final Regulations on Real Property Definition for REIT Purposes

Final regulations establish analytical framework for determining whether assets qualify as real property for purposes of the REIT rules. On August 31, 2016, the Treasury Department and the Internal Revenue Service (IRS)...more

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

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

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

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

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

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