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[Webinar] Leveraging to Attain Basis Step-Up; Income Tax Benefits of Losing an FLP Case - July 11th, 12:00pm CT

by Thompson Coburn LLP on

Please join us for a webinar based on Steve Gorin's Second Quarter 2017 newsletter, Gorin's Business Succession Solutions. In this webinar the presenter will discuss that one can use debt to allow property to obtain a...more

New stamp duties on shares transfer – Acquisition and disposal of equity interests in residential property holding entities

by Dentons on

Purchases of residential properties in Singapore by companies attract Additional Buyer Stamp Duty (ABSD) of 15% rate in addition to usual Buyer Stamp Duty (BSD) of up to 3%. Seller Stamp Duty (SSD) is also payable if...more

Indirect sale of real estate in the Russian Federation in the context of the beneficial ownership rules

by Dentons on

On 17 January 2017 the Commercial Court of Vladimir Oblast delivered a judgement in case No. ?11-6602/2016 (the “Decision”) under the claim of Vladimir Energy RetailCompany1 Public Joint-Stock Company (the “Company”)....more

The Basics of 1031 Exchanges – Part Two: Structuring Partnership/LLC 1031 Exchange Cash-out Transactions

by Ward and Smith, P.A. on

This is part two of a two-part series on Internal Revenue Code Section 1031 tax-deferred exchange transactions. The first article provided an overview of the basic rules that govern 1031 exchanges. This article describes...more

Buy-to-Let Investors Turn to Commercial Property

by Dorsey & Whitney LLP on

Buy-to-let investors are increasingly turning away from residential properties, with some reports stating that the number of those jumping ship to the commercial sector has recently tripled. This shift has been spurred...more

Final IRS Regulations Clarify That Certain Solar Assets May Qualify as Real Property for REIT Purposes

On August 30, 2016, the IRS issued final regulations that clarify and expand the definition of "real property" for purposes of qualifying as a real estate investment trust (REIT). The final regulations substantially follow...more

Waivers of Ownership Limitation Provisions in REIT Charters

by Goodwin on

I. Why Do REITs Have Ownership Limits in the First Place? - Ownership limitation provisions are designed primarily to protect one of a REIT’s most valuable assets – its status as a REIT under the federal income tax...more

Reforms to the Foreign Investment in Real Property Tax Act and REIT Taxation - Tax Update Volume 2016, Issue 1

by Pepper Hamilton LLP on

The reforms generally encourage foreign investment in U.S. real estate. The enacted Protecting Americans from Tax Hikes Act of 2015 (the Act) contains numerous reforms to the Foreign Investment in Real Property Tax Act...more

Brokerage Account is a Safe Account to Temporarily Hold Homestead Sale Proceeds for Reinvestment [Florida]

by Charles (Chuck) Rubin on

An individual sold his interest in a Florida homestead, and put a portion of the proceeds in two Wells Fargo brokerage investment accounts entitled “Fl. homestead account..” The account was invested in mutual funds and unit...more

Plan Ahead to Avoid or Minimize US Estate Tax

If you are not a US resident or a US citizen and are considering buying assets in the US, there are ways to avoid or minimize US estate tax on those assets. ...more

Recent amendments to the Act respecting duties on transfers of immovables

by Dentons on

On March 17, 2016, the Government of Québec presented its 2016-2017 budget, which included important amendments to the Act respecting duties on transfers of immovables (the Act). The Act provides that every municipality...more

UK Budget 2016 – Key Tax Measures

The Chancellor of the Exchequer delivered the UK Budget for 2016 on 16 March 2016. The Budget was delivered against the backdrop of international tax developments, relating to the Organisation for Economic Co-operation and...more

Real Estate Update: Australia's foreign investment regime reloaded and recent developments

by DLA Piper on

On 22 February 2016, the Australian Federal Government announced the introduction of various tax compliance obligations that are to be included as conditions of future Foreign Investment Review Board (FIRB)...more

FIRPTA Withholding Amounts Change

by Burr & Forman on

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (PATH Act) as part of the Consolidated Appropriations Act, 2016. The new PATH Act reforms the Foreign Investment in...more

PATH Act Changes to FIRPTA

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act,” Division Q of the Consolidated Appropriations Act, 2016, P.L. 114-113, enacted December 18, 2015) made some important changes to the U.S. federal income tax...more

Protecting Americans from Tax Hikes Act of 2015 Approved by Congress and Signed by the President

by Dechert LLP on

President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired...more

Congress Passes New Tax Laws Affecting REITs - Protecting Americans from Tax Hikes Act of 2015

by McGuireWoods LLP on

On December 18, President Obama signed the Protecting Americans from Tax Hikes (PATH) Act of 2015 (the “Act”) into law. The Act provides for a number of favorable and flexible REIT-specific tax provisions, and implements...more

Senate Passes Extenders Legislation – Moves to President for Signature

by Goulston & Storrs PC on

Last week the Senate voted 65-33 to pass the Extenders bill (H.R. 2029) and it moves to the President where it is expected to be signed.  As discussed in more detail in this blog, the legislation makes permanent or creates an...more

New REIT Bill Coming?

In late April, Senator Orrin Hatch introduced Senate bill 915, the Real Estate Investment and Jobs Act of 2015. When a foreign person invests in property in the U.S., that person is subject to U.S. tax when he/she/it...more

New Developments In The VAT Treatment Of Securitisation Servicing

by Allen & Overy LLP on

HMRC are expected to consult on revisions to their published guidance to clarify the circumstances in which they will treat loan servicing in securitisation arrangements as exempt for VAT purposes....more

Senate Finance Committee Proposes FIRPTA Reform

by Goulston & Storrs PC on

Today was an important step in moving forward US tax reforms to encourage international investment in U.S. real estate.  The Senate Finance Committee passed 17 different tax bills for consideration by the entire Senate.  ...more

Draft Finance Bill 2015: Key Implications for U.K.-Based Alternative Asset Managers and Their Funds

Following not quite so hotly on the heels of the Autumn Statement as some would like, the U.K. government has now published draft legislation for inclusion in next year’s Finance Bill. ...more

Regulators Decline to Exempt TOBs from Risk Retention Rule but Add Helpful Revisions and Clarifications

by Ballard Spahr LLP on

Although regulators have rebuffed industry efforts to have tender option bonds (TOBs) exempted from the final credit risk retention rule (the CRRR), they have nevertheless provided some helpful changes and clarifications that...more

The future of multifamily housing bonds?

by Ballard Spahr LLP on

Earlier this year, President Obama included within his Administration’s budget to Congress certain tax proposals. Among those was a proposal to allow states to convert up to 8 percent of their private activity bond (PAB)...more

Tax Talk -- Volume 7, No. 2 -- July 2014

by Morrison & Foerster LLP on

In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more

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