Robert Cudd

Robert Cudd

Polsinelli

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Proposed Regulations on Disguised Payments for Services and Management Fee Waivers

On July 23, 2015, the Internal Revenue Service (“IRS”) issued a Notice of Proposed Rulemaking (the “Notice”) which proposed Treasury regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the...more

7/29/2015 - Allocation of Funds Clawback Agreements Entrepreneurs Fee Waivers IRC IRS NPRM Partnership Agreements Profits U.S. Treasury

Treasury Notice on Inversions Leaves Basic Inversion Transactions Intact

In This Issue: - Deferred Earnings and Profits of CFCs - Code Section 956(e) - Code Section 7701(l) - Code Section 304(b)(5)(B) - Code Section 7874 - Request for Comments -...more

10/7/2014 - CFCs Corporate Taxes Inversion Tax Evasion U.S. Treasury

Proposed Regulations Expand Definition Of Real Estate For REITS To Include Solar Sites

In This Issue: - Solar Sites - The Proposed Regulations - Intangible Assets - Distinct Assets - Examples in the Proposed Regulations - Effective Date - Excerpt from Solar Sites: A key...more

5/21/2014 - Property Tax Proposed Regulation Real Estate Investments REIT Solar Energy Solar Farm

Proposed Partnership Liability Regulations

On January 29, 2014, the Internal Revenue Service (IRS) proposed Treasury regulations under Section 752 of the Code which would change the way in which both partnership recourse and nonrecourse liabilities are allocated. The...more

2/11/2014 - IRS Partnerships Tax Liability

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