Key Points -
Recently proposed regulations would significantly curtail the ability for private fund sponsors and non-U.S. investors to use a so-called D-REIT to facilitate a tax-efficient exit from U.S. real property...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
10/25/2018
/ Asset Management ,
Capital Assets ,
Capital Gains ,
Community Development ,
Economic Development ,
Fund Sponsors ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Low-Income Issues ,
New Rules ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Public Finance ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Rollover Equity ,
Safe Harbors ,
State and Local Government ,
Tax Benefits ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Exemptions ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury ,
Value Appreciation
Final regulations issued by the Treasury and the Internal Revenue Service (IRS) on January 19, 2017, revealed a set of new rules interpreting “qualifying income” under Section 7704(d) of the Internal Revenue Code, affecting...more
Key Points -
- Final, temporary and proposed regulations issued on October 5, 2016, address complex rules dealing with partnership disguised sales and debt allocation rules under Sections 707 and 752 of the Internal...more
The Department of the Treasury and the Internal Revenue Service (IRS) announced today (available here) that they are delaying the implementation by two years—until January 1, 2016—of final expanded regulations governing the...more
The Internal Revenue Service (IRS) issued Notice 2013-43 (available here), which delays by six months certain of the timelines during which withholding agents and foreign financial institutions (FFIs) will be required to...more