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IRS Reissues Proposed Regulations for Centralized Partnership Audit Regime

The new rules represent a complete overhaul of partnership audit, assessment, and collection procedures. Taxpayers should review and potentially amend partnership agreements before the new rules are scheduled to take effect...more

Impact of Trump Presidency on Renewable Energy Incentives Remains Uncertain

Last week's election, surprising many with Republican control of the political branches of the federal government, has led to significant uncertainty throughout the private and public sectors. The renewable energy industry...more

Recently Issued Final, Temporary and Proposed Treasury Regulations Regarding the Allocation of Partnership Liabilities and...

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

IRS Issues Final Debt-Equity Regulations

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

Final Regulations Clarify the Definition of “Real Property” Under the REIT Rules

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

Treasury Expands Scope of REIT Spin-Off Rules in New Regulations

On June 7, the Treasury Department released temporary regulations (the “Temporary Regulations”) that expand the types of spinoff transactions subject to the rules under Section 337(d)2 requiring gain recognition where either...more

Renewable Energy Industry Receives an Unexpected Gift of a Five-Year Extension of the ITC and PTC

On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law. Among the numerous changes in tax law contained in the Act are five-year extensions of the 30% investment tax credit (“ITC”),...more

Extenders Bill Puts an End to Tax-Free REIT Spinoffs but Includes a Number of Favorable Changes to the Taxation of REITs

On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law. Notably, the Act contains a number of substantive changes to the tax laws applicable to “real estate investment trusts”...more

Proposed Regulations Clarify the Definition of “Real Property” Under the REIT Rules

On May 14, 2014, the Treasury Department published proposed regulations (the “Proposed Regulations”) clarifying the definition of “real property” under the real estate investment trust (“REIT”) rules. The issuance of the...more

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