Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features the shifting single-family rental landscape, what’s next for EDGAR, and...more
2/22/2024
/ Basel III ,
Beneficial Owner ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Transparency Act ,
Creditors ,
EDGAR ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Housing Market ,
Interest Rates ,
Investment ,
Limited Liability Company (LLC) ,
Liquidity ,
Loans ,
Mortgages ,
Qualified Mortgage Rule ,
Real Estate Investments ,
Rental Property ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Structured Finance ,
Syndicated Loans
Our Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”...more
Our Federal Tax Group mines recent legislative proposals for amendments that could change the way crypto assets are reported – and taxed. Proposed amendments to Section 6045 - The status of mining and staking activities...more
Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed...more
Our Federal Tax Group discusses a new Revenue Procedure from the IRS that provides useful real estate mortgage investment conduit (REMIC) and investment trust safe harbors for mortgage loan payment forbearances (and related...more
SECURITIZATION SIDE NOTES – EU Risk Retention: Did This Come with a Gift Receipt? We’d Like to Return It -
A new year brings new laws and regulations into effect, in this case a complicated and confusing gift from our...more
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
PRACTITIONER NOTES – Frankenstein’s Monster? Rosemary’s Baby? The Twins from the Shining? How Lenders are thinking about the Delaware Division Statute and Division LLCs -
Recent amendments to the Delaware LLC Act (the...more
A continuation of the market trends from last year can be expected in 2018. Structured finance and securitization markets had a period of relative calm in 2017 as new regulations were incorporated into transactions. While no...more
2/7/2018
/ Capital Requirements ,
Consumer Financial Protection Bureau (CFPB) ,
EDGAR ,
Financial Institutions ,
FIRREA ,
Foreclosure ,
Mortgages ,
Securitization ,
Structured Finance ,
Tax Cuts and Jobs Act ,
TILA-RESPA Integrated Disclosure Rule (TRID)
With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and...more
Any firm that is currently claiming certain exemptions or exclusions from registration with the Commodity Futures Trading Commission (CFTC) as a commodity pool operator (CPO) or commodity trading advisor (CTA) is required to...more
LTR 201542004 at first seems to involve a standard spinoff for the purpose of pursuing a reverse Morris Trust combination of Controlled with a Merger Partner, with the “significant issue” for ruling being a proposed swap of...more
Like-kind exchanges are well-known events in the field of investment real estate. The tax law has spent about the last 30 years refining the deferred like-kind exchange, in which the taxpayer is given time to locate the...more
9/2/2015
/ Business Assets ,
Capital Gains ,
Commercial Real Estate Market ,
Cross-Border Transactions ,
Foreign Affiliates ,
Goodwill ,
Intangible Property ,
Real Estate Investments ,
Related Parties ,
Section 1031 Exchange ,
Tax Planning