News & Analysis as of

Tax Structuring

Orrick's Financial Industry Week In Review

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

Civil Forfeiture Under Fire – Part II

by Ballard Spahr LLP on

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

New Treasury Regulations Curtail Planning Opportunities for Partnership Structures

by Dechert LLP on

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

DOJ Announces Major Policy Change on Use of Asset Forfeiture for Structuring Offenses

by Blank Rome LLP on

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

Focus on Tax Strategies & Developments - November 2014

by McDermott Will & Emery on

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

Seeing the Forest through the Trees -- A New Method for Structuring Investment by Foreign Investors in U.S. Timber and...

by Gerald Nowotny on

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

Daishowa-Marubeni: A Tree Fell In The Forest And The SCC Caught It!

by Dentons on

In Daishowa-Marubeni International Ltd. v. The Queen, 2013 SCC 29, Justice Rothstein marries tax philosophy and tax practice by asking and answering the question: If a tree falls in the forest and you are not around to...more

Tax Kung Fu – Tax Structuring for Chinese Investment in U.S. Real Estate

by Gerald Nowotny on

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

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