News & Analysis as of

RICs

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

International Tax Advisory: New Law Brings Some Welcome FIRPTA Changes

by Alston & Bird on

On December 18, President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Despite the new law’s name, a number of its provisions affect foreign investors. The PATH Act introduces several...more

Omnibus Bill Includes Significant Changes to Tax Law Regarding FIRPTA, REITs, and RICs

by Ropes & Gray LLP on

On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “Act”). The Act includes significant changes to tax laws relevant to private equity, real estate and mutual fund...more

Protecting Americans from Tax Hikes Act of 2015 Approved by Congress and Signed by the President

by Dechert LLP on

President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired...more

IRS Addresses RIC Asset Diversification Requirements

On September 14, the Internal Revenue Service (IRS) issued final regulations under Internal Revenue Code Section 851 clarifying that control groups under the regulated investment company (RIC) rules may consist of two...more

IRS Adds Certain Spin Transactions to the “No Rule” List

by Latham & Watkins LLP on

Treasury and IRS announce that certain “cash rich” and REIT/RIC conversion spin-offs are under study and are added to the “no rule” list. On September 14, 2015, the United States Treasury Department (the Treasury) and...more

IRS Suspends Private Rulings on Many REIT Spin Off Conversions

by 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

New IRS Guidance Limits Tax-Free Spin-Off Rulings – Implications for REIT Spin-Offs

by Morrison & Foerster LLP on

On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more

Volcker Rule: Federal Agencies Issue New Guidance Regarding the Seeding Period Treatment for Registered Investment Companies...

by Morrison & Foerster LLP on

Under guidance issued on July 16, 2015 by the federal agencies responsible for implementing the Volcker Rule (the “Agencies”) RICs and FPFs need not be treated as banking entities during a seeding period of up to three...more

Agencies Provide Guidance On Seeding Period for Volcker Rule

The staffs of the agencies responsible for administering the Volcker Rule have again updated the Volcker Rule FAQs. A new FAQ notes that the rule implementing the Volcker Rule and the accompanying preamble make clear that a...more

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