On April 24, 2024, the Treasury Department released final regulations that alter key rules affecting many real estate funds and foreign investors in U.S. real estate....more
On May 3, 2023, the U.S. Tax Court upheld a taxpayer’s reliance on Revenue Procedure 93-27 to characterize as a profits interest a partnership interest granted in exchange for services that were provided indirectly for the...more
On December 28, 2022, the Treasury Department released a set of proposed regulations that, if finalized, would alter key rules affecting many real estate funds, sovereign wealth funds and other foreign investors in U.S. real...more
Decisions by state and local governments in the U.S. to control the spread of the COVID-19 virus through shelter-in-place orders and business closures have resulted in both a sharp increase in unemployment and a sharp...more
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was signed into law on March 27, 2020, representing the so-called “Phase 3” of the response to the COVID-19 pandemic, as discussed in our client alert “CARES...more
4/2/2020
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
CARES Act ,
Controlled Foreign Corporations ,
Coronavirus/COVID-19 ,
Debt Restructuring ,
EBITDA ,
GILTI tax ,
High-Yield Markets ,
Interest Income ,
International Tax Issues ,
Net Operating Losses ,
Relief Measures ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Relief
The question is no longer whether the volatility created by the COVID-19 pandemic will deepen the difficulties businesses and other institutions face in the coming months, but by how much and in what ways. In the past few...more
3/21/2020
/ Acquisitions ,
Antitrust Provisions ,
Audits ,
Board of Directors ,
Coronavirus/COVID-19 ,
Corporate Restructuring ,
Corporate Taxes ,
Court Closures ,
Debt-Equity ,
Energy Projects ,
Families First Coronavirus Response Act (FFCRA) ,
IRS ,
Liquidity ,
Mergers ,
Power Infrastructure ,
Securities Litigation ,
Shareholder Activism ,
Shareholder Meetings ,
Stock Repurchases
The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more
11/13/2018
/ Asset Valuations ,
C-Corporation ,
Capital Gains ,
Community Development ,
Investment Funds ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
QOZBP ,
Qualified Opportunity Funds ,
Real Estate Investments ,
REIT ,
RICs ,
S-Corporation ,
Startups ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
U.S. Treasury
The Tax Cuts and Jobs Act enacted in late December 2017 created a new capital gains exemption for taxpayers who make long-term investments in low-income communities that have been designated by the Treasury Department as...more
On June 18, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) released proposed regulations that largely reinstate pre-2017 law regarding the allocation of liabilities under the partnership...more
Six months after the most significant U.S. tax reform legislation since 1986 was signed into law, it is still too early to predict the long-term effects. A number of technical uncertainties remain, and taxpayers are...more
6/20/2018
/ Acquisitions ,
Capital Structures ,
Corporate Structures ,
Corporate Taxes ,
Double Taxation ,
Foreign Investment ,
GILTI tax ,
Inversion ,
Local Taxes ,
Mergers ,
Multinationals ,
Partnerships ,
Pass-Through Entities ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates ,
Tax Reform
On August 11, 2017, the Internal Revenue Service released guidance allowing publicly offered real estate investment trusts and regulated investment companies to distribute earnings in a combination of cash and stock as long...more
On May 9, 2014, the U.S. Department of the Treasury (Treasury) released proposed regulations defining the term “real property” for purposes of the REIT rules. The proposed regulations, which provide a framework for taxpayers,...more
Over the last several years, a confluence of political and market developments have made capital for renewable energy projects harder to come by, which has affected the ability of unregulated affiliates of public utilities...more