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Internal Revenue Service Investment Companies

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.  
Cozen O'Connor

Forming a Partnership/LLC: A Checklist for Avoiding Pitfalls

Cozen O'Connor on

Forming a partnership1 without triggering income appears straightforward and simple. In many cases, it is. In other cases, though, forming a partnership can cause one or more partners to unintentionally recognize income. This...more

Dechert LLP

Stock Repurchase Excise Tax Regulations Finalized: Effect on RICs

Dechert LLP on

On June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations on the reporting of the one-percent (1%) stock repurchase excise tax imposed by new section 4501 of the Internal...more

Latham & Watkins LLP

Final Regulations Issued on Domestically Controlled REIT Determinations and Energy Credit Transfers

Latham & Watkins LLP on

Two sets of recently finalized regulations provide guidance for REITs. Key Points: - Final FIRPTA regulations provide rules for determining whether a REIT is domestically controlled, including a look-through rule for...more

Goodwin

IRS Finalizes Regulations for Domestically Controlled REITs and other Qualified Investment Entities

Goodwin on

On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more

Gray Reed

Thoughts on Cryptocurrency and Tax Partnerships

Gray Reed on

Cryptocurrency holders often want to put their assets into an entity for a host of reasons, such as asset protection, arranging negotiated management rights and exit planning.  This post discusses basic federal income tax...more

Freeman Law

Partnership Formations and the Income-Company Exception

Freeman Law on

Partnership Formation - The formation of a partnership is generally a nonrecognition transaction for both the contributing partner and the newly-created partnership. Thus, as a general rule, no gain is recognized by a...more

Dechert LLP

Final IRS Regulations for RICs to Passthrough REIT Dividends Eligible for 20% Deduction

Dechert LLP on

The U.S Department of the Treasury and the Internal Revenue Service on June 24, 2020 issued final tax regulations ("Final Regulations") that permit a regulated investment company (“RIC”) to report to its shareholders the...more

Kramer Levin Naftalis & Frankel LLP

Income Inclusions From a Controlled Foreign Corporation or Passive Foreign Investment Company are “Good” Income for a Regulated...

Recently-finalized, regulations provide that, in determining whether a corporation is a regulated investment company (RIC), amounts the corporation is required to include in income as a result of its investment in foreign...more

McDermott Will & Emery

Weekly IRS Roundup April 22 – 26, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 22–26, 2019. April 22, 2019: In an effort to reduce paperwork and respondent burden the...more

Buchalter

Comments on Proposed 199A Regs Regarding Qualified REIT Dividends Due Soon

Buchalter on

Comments are due on April 9, 2019 with respect to the recent proposed regulations regarding eligibility of qualified REIT dividends for the qualified business income deduction under Code Section 199A. On January 18, 2019...more

Morgan Lewis

IRS, Treasury Issue Final Guidance Regarding Certain Investments by RICs

Morgan Lewis on

In a big win for the industry, final regulations issued by the Internal Revenue Service and US Department of Treasury do not adopt all the rules set forth in the proposed regulations. Instead, regulated investment companies...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

Burr & Forman on

On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

Farrell Fritz, P.C.

Loans Between Related Entities

Farrell Fritz, P.C. on

What Was Intended? Over the last thirty years, I have reviewed the income tax returns of many closely held corporations and partnerships. Quite often, on Schedule L (the balance sheet), I will see an entry for “other...more

Farrell Fritz, P.C.

When Investing In A Partnership May Be A Tax Problem

Farrell Fritz, P.C. on

A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

Troutman Pepper

The IRS's Stricter(?) Stance on Regulated Investment Company Investments in Commodities - Tax Update Volume 2017, Issue 1

Troutman Pepper on

While the IRS's Proposed Regulations Are Not Yet Effective, RICs Should Carefully Consider Whether Their Portfolios or Policies Run Afoul of the New Rules. In order for a corporation to qualify as a regulated investment...more

Dechert LLP

IRS Issues Proposed Regulations Relating to the Treatment by Regulated Investment Companies of Income from Subsidiaries Investing...

Dechert LLP on

The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the “Proposed Regulations”), and a Revenue Procedure that address the treatment to regulated investment companies (“RICs”)...more

Morgan Lewis

Fast Action May Be Needed to Avoid Proposed Valuation Rules

Morgan Lewis on

On August 2, the IRS issued proposed regulations that, if made final, could result in substantial increases in gift or estate taxes for owners of interests in some family owned corporations, partnerships, limited liability...more

Goodwin

IRS Addresses RIC Qualification Matters Related to Derivatives and Use of Blocker Corporations

Goodwin on

On Wednesday, September 28, the IRS and Treasury Department proposed regulations under Section 851 of the Code that, if finalized, could prospectively invalidate dozens of private letter rulings treating subpart F and passive...more

Alston & Bird

Federal Tax Advisory: Investment Company Rules

Alston & Bird on

Sections 351 and 362 contain investment company rules that have nothing to do with mutual funds. They define certain corporations as investment companies in counterintuitive ways and then deny the usual nonrecognition...more

Morrison & Foerster LLP

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

Lowndes

IRS No Rule Policy Expected to Cool Down Spin-offs

Lowndes on

On Monday, the IRS released Notice 2015-59. In it, the IRS announced that the IRS will no longer issue private letter rulings on whether a distribution satisfies the requirements of Section 355 for a tax-free spin-off where...more

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