Michelle Jewett

Michelle Jewett

Morrison & Foerster LLP

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Recently Proposed Treasury Regulations Regarding the Allocation of Partnership Recourse and Nonrecourse Liabilities Contain...

On January 29, 2014, the Internal Revenue Service (“IRS”) and the Treasury Department issued proposed regulations (the “Proposed Regulations”) modifying the rules under Section 752 regarding the allocation of recourse and...more

2/11/2014 - IRS Partnerships Personal Liability Professional Liability Recourse Proceedings

A Snapshot Of Baucus's Vision For Energy Tax Incentives

On Dec. 18, Senate Finance Committee Chairman Max Baucus, D-Mont., released a discussion draft of legislation that aims to reform U.S. energy tax incentives. The proposed energy tax incentives are a simpler set of incentives...more

1/17/2014 - Clean Energy Energy Energy Policy Renewable Energy Tax Credits Tax Incentives

Senator Baucus Proposes New Regime for Energy Tax Incentives

On December 18, Senate Finance Committee Chairman Max Baucus, D-Mont., released a discussion draft of legislation that aims to reform U.S. energy tax incentives. The proposed energy tax incentives are a simpler set of...more

12/23/2013 - Clean Energy Energy Policy Energy Tax Incentives

MoFo’s Quick Guide to: REIT IPOs

Real Estate Investment Trusts (“REITs”) are endlessly inventive. They were first developed in the 1960s as a means for ordinary retail investors to hold interests in real estate. The REIT market has waxed and waned over the...more

12/6/2013 - IPO Real Estate Market Registration REIT SEC

IRS Delays FATCA Implementation

On July 12, 2013, the IRS released Notice 2013-43 (the “Notice”), which sets forth a revised timeline for the implementation of the Foreign Account Tax Compliance Act (“FATCA”). The most significant development is that...more

7/15/2013 - Delays FATCA Grandfathered Obligations IRS

Application of the Self-Employment Tax and 3.8% Net Investment Income Tax to Fund Managers

With the imposition of a new 3.8% “net investment income tax” (the “NIIT”) pursuant to Section 1411 of the Internal Revenue Code of 1986, as amended (the “Code”) on passive income and the imposition of an additional .9% on...more

3/7/2013 - Fund Managers Net Investment Income Self-Employment Tax

American Taxpayer Relief Act of 2012: Extends Production Tax Credit for Wind and Many Other Cleantech Tax Incentives

On January 1, 2013, the Senate and the House of Representatives passed the American Taxpayer Relief Act of 2012 (“ATRA”), averting the so-called “fiscal cliff.” The legislation, which was signed by President Obama, extends...more

1/7/2013 - American Taxpayer Relief Act Clean Tech Electricity Fiscal Cliff Production Tax Credit Renewable Energy Sequestration Wind Power

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