News & Analysis as of

Passive Activity Internal Revenue Service

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

When the Internal Revenue Code and the FAA Regulations Collide - What Results?

by Sanford Millar on

The Federal Aviation Administration (FAA) categorizes aircraft owners and operators into different categories. In general, the FAA grants an owner of an aircraft who operates the aircraft for personal use and enjoyment a...more

Court Finds All of a Taxpayer’s Work for His Employer to be Personal Services in a Real Estate Business

by Miles & Stockbridge P.C. on

The U.S. District Court for the Western District of Arkansas recently held that all of a taxpayer’s work for his employer, a property management company, counted toward the taxpayer’s satisfaction of the material...more

Commenters Weigh in on Proposed Regulations for Determining MLP Qualifying Income

by Latham & Watkins LLP on

IRS’ proposed MLP regulations generate flurry of specific industry-related comments and spur public hearing. “I’m mad as Hell, and, frankly, I’m not going to take it anymore.” — Paraphrase of concerned citizen and...more

Master Limited Partnerships: Proposed Tax Regulations Scale Back Activities Giving Rise to Qualifying Income

The Treasury Department (Treasury) and the Internal Revenue Service (Service) have issued proposed tax regulations (Proposed Regulations) that provide guidance on, and significantly scale back, the types of activities...more

Publicly Traded Partnership Proposed Regulations

by Dechert LLP on

Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more

IRS Publishes Proposed Regulations for Hedge Fund Reinsurance Arrangements

by BakerHostetler on

In April 24’s Federal Register, the IRS released proposed regulations (REG-108214-15) to restrict when a foreign insurance company’s income can be excluded as passive income by giving a more strict definition for the “active...more

Proposed Anti-Inversion Regulations Would Affect Foreign Insurers

by Carlton Fields on

For decades American companies have used so-called “corporate inversions” to lower their tax burdens on foreign-earned income. Typically, the American company is acquired by a foreign company located in a tax-favorable...more

In Frank Aragona Trust, Tax Court Holds that Trustees’ Activities as Employees Count for Purposes of Material Participation Under...

by Pepper Hamilton LLP on

The issue of whether a trust has passive or non-passive income from its investment in a pass-through entity has taken on increased importance in light of the tax imposed on net investment income under Code Section 1411 of the...more

Participation of 100 Hours May Be Sufficient to Generate Active Income Exempt from the 3.8 Percent Health Care Tax on Net...

by McDermott Will & Emery on

As business owners begin filing their 2013 federal income tax returns and pay the 3.8 percent tax on net investment income for the first time, they should be aware that 100 hours of participation in an activity may be...more

New 3.8% Medicare Tax on Investment and Unearned Income Beginning in 2013

by Thompson Coburn LLP on

Starting January 1, 2013, a new 3.8% Medicare tax will apply to the investment and “unearned income” of individuals, trusts and estates. The tax is intended to apply to income exempt from the regular FICA or self-employment...more

11 Results
|
View per page
Page: of 1
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.