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Internal Revenue Service Corporate Conversions

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Fenwick & West LLP

Domestication with a Twist: A Tax Case Study

Fenwick & West LLP on

The Internal Revenue Service’s new private letter ruling (PLR) concerned a domestication of a Foreign Parent corporation under U.S. ownership—with a few notable twists. First, the PLR applied a substance-over-form analysis to...more

Farrell Fritz, P.C.

LLC-To-Partnership Conversion: There’s More To It Than Meets The Eye

Farrell Fritz, P.C. on

Some Days Are Stones[1]- It’s not always easy to find a topic about which to write a weekly blog post. I usually look for a ruling or decision that illustrates one of the recurring themes of the tax law, and then develop a...more

Morgan Lewis

IRS Issues Temporary and Proposed Regulations Focused on REIT/RIC Conversion Transactions

Morgan Lewis on

The regulations affect both real estate investment trusts (REITs) and regulated investment companies (RICs) that receive appreciated property from a C corporation in a so-called “conversion transaction.”...more

Goulston & Storrs PC

IRS Suspends Private Rulings on Many REIT Spin Off Conversions

Goulston & Storrs PC on

The flurry of Opco-Propco REIT conversions has hit a stumbling block this week when the IRS issued a Revenue Procedure announcing a “no rule” policy for a key corporate tax issue for many REIT spin offs. Basically to do a...more

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