On October 5, 2016, the Internal Revenue Service (“IRS”) and Treasury Department published final regulations (the "Final Regulations"), temporary regulations (the "Temporary Regulations") and new proposed regulations (the...more
10/25/2016
/ Business Taxes ,
Debt Financing ,
Disguised Sales ,
IRS ,
New Regulations ,
Partnership Agreements ,
Partnership Liabilities ,
Partnerships ,
Proposed Regulation ,
Risk Allocation ,
U.S. Treasury
On October 13th, the Internal Revenue Service (“IRS”) followed through on its promise to issue final regulations and temporary regulations under Section1 385 (the “Final Regulations” and “Temporary Regulations,” respectively)...more
10/24/2016
/ Credit Agreements ,
Creditors ,
Debt Instruments ,
Debt-Equity ,
Debtor-Creditor ,
Disregarded Entities ,
Enforcement ,
Expanded Group Instruments (EGIs) ,
IRS ,
Proposed Regulation ,
Rebuttable Presumptions
IRS Issues Proposed Regs on RIC Commodity Investments -
On September 27, 2016, the IRS issued proposed regulations (the “Proposed Regulations”) providing guidance relating to the income test and asset diversification...more
10/13/2016
/ Capital Gains ,
CFCs ,
Corporate Taxes ,
Estate Tax ,
Hillary Clinton ,
Income Taxes ,
IRS ,
Marital Status ,
PFIC ,
Political Candidates ,
Presidential Elections ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
REIT ,
TEFRA ,
Trump Administration
On August 31, 2016, the Treasury Department published final regulations (the “Final Regulations”) clarifying the definition of “real property” under the real estate investment trust (“REIT”) rules. The Final Regulations...more
9/15/2016
/ Crops ,
Data Centers ,
Final Rules ,
Intangible Property ,
IRS ,
Pipelines ,
Private Letter Rulings ,
Proposed Regulation ,
REIT ,
Solar Farm ,
U.S. Treasury
On April 4th, the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 385 which could dramatically change how related-party indebtedness is treated for federal income tax...more