News & Analysis as of

RICs

Ding, Dong, the Witch is Dead

by Charles (Chuck) Rubin on

--Here lies the remains of the Code §2704 Proposed Regulations. RIP, 2016-2017-- As part of President Trump’s mandated review of federal regulations, the Secretary of Treasury has issued a report specifically recommending...more

Potential Help for Cash-Strapped RICs and REITs - Tax Update Volume 2017, Issue 5

by Pepper Hamilton LLP on

Recently, the IRS provided a method for publicly offered real estate investment trusts (REITs) and publicly offered registered investment companies (RICs) to fulfill their distribution requirements while distributing stock as...more

Treasury To Repeal/Revise 8 Burdensome Regs

As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...more

Part Cash, Part Stock, 100% Taxable – New IRS Guidance on RIC and REIT Distributions

by Dechert LLP on

The U.S. Internal Revenue Service (“IRS”), on August 11, 2017, issued Revenue Procedure 2017-45 (the “New Revenue Procedure”).1 Pursuant to the New Revenue Procedure, the IRS will treat part cash and part stock distributions...more

IRS Issues Guidance on RIC and REIT Stock Distributions

by Morgan Lewis on

The IRS has issued Revenue Procedure 2017-45, which provides that certain distributions of stock by a publicly offered RIC or publicly offered REIT made pursuant to a “cash or stock election” will be treated as a taxable...more

IRS Issues Guidance on Stock/Cash Dividends for REITs and RICs

On August 11, 2017, the Internal Revenue Service released guidance allowing publicly offered real estate investment trusts and regulated investment companies to distribute earnings in a combination of cash and stock as long...more

IRS Provides Guidance on Stock Distributions for Publicly Offered REITs and RICs

by Latham & Watkins LLP on

Revenue procedure sets forth requirements for ensuring certain stock distributions are treated as property distributions eligible for dividends paid deduction. On August 11, 2017, the Internal Revenue Service (IRS)...more

Good News for Taxpayers: IRS Targets for Reform Burdensome Regulations on Partnerships, Corporations, REITs, Estates, and More

Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more

MoFo New York Tax Insights - Volume 8, Issue 5

by Morrison & Foerster LLP on

Final 2017-18 New York State Budget Bill Enacted - The New York State Budget Bill was enacted by the New York State Legislature and signed into law by Governor Andrew M. Cuomo. S. 2009-C, A. 3009-C. Among the Governor’s...more

Hodgson Russ LLP’s Report on the 2017-18 New York State Budget

by Hodgson Russ LLP on

On April 10th, the New York State budget for 2017-18 was signed into law. The highlights of the revenue provisions are summarized below....more

MoFo Tax Talk: Volume 9, Issue 4

by Morrison & Foerster LLP on

EDITOR’S NOTE - Tax Talk doesn’t remember much about 1985. But we do remember that, after Ronald Reagan was re-elected president in 1984, tax reform was a very hot topic (remember the Tax Reform Act of 1985?). Anyway,...more

IRS Issues Final Regulations on REIT and RIC Conversion Transactions

by Proskauer - Tax Talks on

The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing from ten years to five years the recognition period for the corporate-level tax...more

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

by Pepper Hamilton LLP 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

One Step Back, One Step Forward: New Debt-Equity Regulations Narrow Their Focus on Earnings Stripping

by Seyfarth Shaw LLP on

Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more

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

by 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

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Federal Tax Guidance Regarding RICs’ Investments in Commodities, Certain PFICs, and “Securities”

by K&L Gates LLP on

The Treasury Department (Treasury) and the Internal Revenue Service (Service) recently issued proposed regulations that, if finalized as proposed, could have a significantly adverse effect on the ability of a regulated...more

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

by 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

IRS and Treasury Issue Guidance Regarding CFC and PFIC Investments by RICs

by Morgan Lewis on

The recently proposed regulations, if finalized, would govern the treatment of RICs’ income inclusions in respect of CFCs and PFICs for purposes of the income test applicable to RICs; in related guidance, the IRS also...more

"IRS Expands REIT Spin-Off Restrictions, Extends REIT Built-in Gains Period to 10 Years"

On June 7, 2016, the Internal Revenue Service (IRS) and Treasury Department issued new temporary regulations that have dramatic implications for all merger-and-acquisition activity by C corporations and real estate investment...more

IRS Offers Tax Guidance Relating to Money Market Fund Rules

by Morgan Lewis on

The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more

PATH Act Amends FIRPTA

Congress enacted the Foreign Investment in Real Property Tax Act (FIRPTA) in 1980 to impose U.S. income tax on certain foreign persons that invest in United States real property interests (USRPI). The FIRPTA tax is collected...more

PATH Act Brings FIRPTA Changes

by Alston & Bird on

The Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), signed December 18, 2015, introduces significant changes to the Foreign Investment in Real Property Tax Act (FIRPTA), particularly concerning REITs. ...more

MoFo Tax Talk - Volume 8, No. 4

by Morrison & Foerster LLP on

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more

IRS Publishes Guidance for RICs that Receive Foreign Tax Credit Refunds

by Morgan Lewis on

IRS announces the issuance of new regulations that will provide relief for certain regulated investment companies that receive foreign tax refunds by either netting the refund against foreign taxes paid in the year of the...more

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