Tax Talk -- Volume 6, No. 2 -- July 2013

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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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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