News & Analysis as of

U.S. Treasury Protecting Americans from Tax Hikes (PATH) Act

Paul Hastings LLP

New Treasury Guidance on Sovereign Wealth Funds, Qualified Foreign Pension Funds, and REITS and RICs

Paul Hastings LLP on

On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more

Proskauer - Tax Talks

Proposed Regulations Provide Clarity for Qualified Foreign Pension Fund Exception

Proskauer - Tax Talks on

On June 7, 2019, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed Treasury regulations under Sections 897, 1445 and 1446 (the “Proposed Regulations”) regarding the exception...more

Morrison & Foerster LLP

Treasury Report Proposes Substantial Revisions to Controversial Tax Regulations

Morrison & Foerster LLP on

Last week, on October 2, 2017, the U.S. Department of the Treasury (the “Treasury”) delivered a report to President Trump that proposes substantial revisions to eight sets of controversial U.S. federal income tax regulations...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Corrects Effective Date of Recently Issued Built-in Gain Regulations"

The Internal Revenue Service (IRS) and Treasury Department today issued a much-welcomed technical correction to the effective date of the recently issued “built-in gain” regulations regarding real estate investment trust...more

Morrison & Foerster LLP

Treasury Expands Scope of REIT Spin-Off Rules in New Regulations

On June 7, the Treasury Department released temporary regulations (the “Temporary Regulations”) that expand the types of spinoff transactions subject to the rules under Section 337(d)2 requiring gain recognition where either...more

Morgan Lewis

IRS Issues Temporary and Proposed Regulations Focused on REIT/RIC Conversion Transactions

Morgan Lewis on

The regulations affect both real estate investment trusts (REITs) and regulated investment companies (RICs) that receive appreciated property from a C corporation in a so-called “conversion transaction.”...more

Locke Lord LLP

The U.S. Treasury Releases New FIRPTA Regulations

Locke Lord LLP on

On February 17, 2016, the U.S. Treasury released new regulations (the New FIRPTA Regulations) that reflect changes that the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) made to the Foreign Investment in Real...more

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