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Tax Talk: Volume 10, Issue 2

EDITOR’S NOTE - With the failure of health care legislation to “repeal and replace” the Affordable Care Act, eyes in Washington, D.C. are now turning to tax reform. Since Congress plans to take August off, any real tax...more

8/15/2017  /  Audits , IRS , Partnerships , REIT , Tax Court , TEFRA

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

MoFo Tax Talk: Volume 10, Issue 1

EDITOR’S NOTE - We held up Tax Talk this quarter in order to bring you the latest on the Trump administration’s tax reform plans. Unfortunately, the one-page plan and transcript of the press conference released on April 26...more

Trump Administration Releases One-Page Tax Plan

On April 26, 2017, amidst much anticipation, the Trump administration released its tax plan, entitled “2017 Tax Reform for Economic Growth and American Jobs” (the “Plan”). The Plan was presented at a press conference by...more

MoFo Tax Talk: Volume 9, Issue 4

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

IRS Provides Guidance on TLAC

On December 16, 2016, the Internal Revenue Service (“IRS”) issued Revenue Procedure 2017-12 (the “Revenue Procedure”), which provides that certain instruments issued by global systemically important banking organizations...more

12/22/2016  /  Income Taxes , IRS , TLAC

IRS Guidance for Implementation of the Section 871(m) Regulations

On December 2, 2016, the Internal Revenue Service (“IRS”) released an advance version of Notice 2016-76 (the “Notice”) and followed through on its promise to provide taxpayers with guidance for complying with final and...more

Quick Guide to REIT IPOs - 2016

Real Estate Investment Trusts (“REITs”) are endlessly inventive. They were first developed in the 1960s as a means for ordinary retail investors to hold interests in real estate. The REIT market has waxed and waned over 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

MoFo Tax Talk - Volume 9, No. 3

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

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

MoFo Tax Talk - Volume 9, No. 2

Editor's Note - Welcome to Tax Talk 9.02. By this fall, we may look back on Q2 2016 with some nostalgia. Of course, there is the U.S. presidential election on November 8th, but U.S. tax advisors right now are more...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

MoFo Tax Talk - Volume 9, No. 1

IRS Publishes Proposed section 305(c) Regulations - On April 12th, the IRS published proposed regulations under Section 305(c) that address the treatment of deemed dividends to holders of stock and rights to acquire...more

Latest Treasury Action on Inversions Upends Pending Transactions and Surprises Many for Its Broad Scope and Use of Questionable...

On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions (the “Regulations”). Many features of the Regulations had...more

Proposed IRS Debt-Equity Regulations: Aimed at PostInversion “Earnings Stripping,” But May Also Impact Ordinary Related-Party Debt

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

MoFo Tax Talk - Volume 8, No. 4

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....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

Quick Guide to REIT IPOs - 2015

Real Estate Investment Trusts (“REITs”) are endlessly inventive. They were first developed in the 1960s as a means for ordinary retail investors to hold interests in real estate. The REIT market has waxed and waned over the...more

Congress Overhauls the Partnership Tax Audit Rules

On November 2, 2015, President Obama signed the Bipartisan Budget Act of 2015 (the “Bill”), which repeals the TEFRA Unified Audit Procedures and replaces them with a radically modified “corporate” model for partnership tax...more

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, and Some Ugly

On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m), the Internal Revenue Code provision that treats “dividend equivalents” paid under certain contracts as...more

New IRS Guidance Limits Tax-Free Spin-Off Rulings – Implications for REIT Spin-Offs

On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more

MoFo Tax Talk - Volume 8, Issue 2

IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,”...more

Negative Interest Rate Consequences

Over the last few months, the financial press has been filled with reports of negative interest rates. For example, on December 18 2014, the Swiss National Bank announced that it would move from a zero percent interest rate...more

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