In This Issue:

IRS Leaves Potential REIT Conversions Hanging; IRS Proposes to Relax Wash Sale Rules for Floating NAV Money Market Fund Share Redemptions; IRS Confirms Mexican Land Trust Is Not Trust Under U.S. Tax Law; Third Circuit: S Corp Flow-Through Tax Treatment Not Property of Debtor Under the Bankruptcy Code; Treasury Signs FATCA IGAs with Spain, Germany and Japan; Structured Finance Transaction Treated as “Conversion Transaction,” Taxed as Straddle; IRS Limits Taxpayer’s Holding Period, Denies DRD; IRS Disallows DRD on Substance Over Form Grounds; Acquisition of Medium Term Notes by Foreign Bank’s U.S. Branch Eligible For “10% Rule”; U.S. District Court Finds Tax Opinion Condition Could Not Have Been Met in MBIA v. Patriarch Partners; MoFo in the News; and Awards.

Excerpt from IRS Leaves Potential REIT Conversions Hanging -

Recent federal securities law filings by two companies – one in the document management and storage business,4 the other an operator of data centers5 – suggest that the IRS has temporarily suspended REIT conversion rulings while it analyzes the meaning and scope of “real estate” under tax rules governing REITs.

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