"In what has been a recently challenging fundraising environment, credit funds are still a bright spot for GPs. The new buzz about credit fund formation relates to the creation of 'evergreen' structures...more
This webinar will go into detail about the advantages and disadvantages of using an F-reorganization as a tax strategy when selling your S-Corporation and will discuss the following topics: - What is an F-reorg for...more
Most of you know by now that I grew up in the Panama Canal Zone which no longer exists as of 1999. In that respect, the transition left me as a man without a country. My father (of blessed memory) when referring to kids...more
Three months into the outbreak of the Coronavirus (COVID-19) in the United Kingdom, there are clearly many unknowns as businesses seek a return to normality or, at the very least, economic stability. Such uncertainty may...more
Tax structuring under the previous regime - Prior to the issuance of the final regulations described below, under Section 956 of the Internal Revenue Code of 1986 and its related Treasury Regulations, for U.S. tax...more
It's always hard to predict what any year will look like, but our current expectation is that globally we will continue to see a very active private equity market in 2019, driven by a continuing low interest rate environment...more
On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law 115-97, the Tax Cuts and Jobs Act (TCJA), amended Internal Revenue Code (Code)...more
Recently proposed legislation would provide taxpayers who made an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over eight years through installment payments the ability to claim a...more
The Internal Revenue Service (IRS) has issued PMTA 2018-016, reaffirming its position that for taxpayers making an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over eight years through...more
A domestic corporation's royalty income derived in connection with business conducted outside the United States generally is eligible for the reduced 13.125 percent effective tax rate on foreign derived intangible income...more
Changes made by tax reform have caused companies to reevaluate their structures. This reevaluation extends to the most fundamental decision: choice of entity. The choice of entity decision now frequently hinges on two key,...more
Structuring Inbound Investment by Foreign Investors Using Private Placement Insurance Products - Overview - By now most of you that have followed my articles know that I grew up in the Panama Canal Zone and studied...more
The review of strategic alternatives can be a daunting task even for the most seasoned executives and directors of real estate companies and real estate investment trusts. This is particularly true in today’s real estate...more
In recent years, the European Commission (EC) has been actively enforcing European Union state aid violations, an area of law that is unique to Europe but has wide-ranging implications for multinationals with investments in...more
Financial Industry Developments - Changes Proposed to CAS and STACR Programs - On May 8, 2017, Fannie Mae and Freddie Mac announced that they are considering certain changes to the structure of their CAS and STACR...more
In this post, we consider the Department of Justice’s (DOJ) Office of the Inspector General report (OIG Report), released on March 29, 2017, evaluating the DOJ’s oversight of its cash seizure and forfeiture operations. This...more
In recent years, much attention has been paid to state legislatures across the country that attempt to alter their existing tax structures by enacting legislation that not only changes how businesses are taxed prospectively,...more
The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more
We previously reported that the Internal Revenue Service had been criticized for its controversial, yet legal, practice of seizing bank accounts when the account holder is suspected of engaging in “structuring.” ...more
REIT Spin-Offs: Recent Transactions and IRS Rulings - Several recent corporate spin-offs in the United States have involved real estate investment trusts (REITs). Provided several requirements are satisfied, including...more
Overview - Large institutional investors including pension plans and endowments and foundations have made significant investments in timberland over the last forty years. These same investors have also made significant...more
Overview - Unless you have been traveling the galaxies for the last twenty years, you haven’t missed the “Chinese Miracle”. Its enormous impact is felt globally. When you see the skyline of Shanghai, the new meaning of...more