On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA. ...more
On October 19, 2018, the Internal Revenue Service (the “IRS”) and the Treasury Department issued proposed regulations relating to the new Opportunity Zone program....more
10/30/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investment Opportunities ,
IRS ,
Low Income Housing ,
New Market Tax Credits ,
Opportunity Zones ,
Proposed Regulation ,
Public Finance ,
Real Estate Development ,
Real Estate Market ,
Safe Harbors ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury
On October 13, 2016, Treasury and the IRS issued new final and temporary “anti-inversion” regulations under section 385 of the Internal Revenue Code that could treat certain purchasers of notes issued by securitizations as...more
10/25/2016
/ Anti-Inversion Regulations ,
Asset-Backed Securities ,
Capital Markets ,
Collateralized Loan Obligations ,
Disregarded Entities ,
Grantor Trusts ,
IRS ,
Partnerships ,
Securitization ,
Stocks ,
Student Loans ,
Tax Rates ,
Transfer Restrictions ,
U.S. Treasury ,
Withholding Tax
On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more
10/25/2016
/ Asset Stripping ,
CDIs ,
Collateralized Loan Obligations ,
Convertible Debt ,
Debt Instruments ,
Debt-Equity ,
Exemptions ,
Expanded Group Instruments (EGIs) ,
Foreign Issuers ,
Interest Payments ,
Internal Revenue Code (IRC) ,
Inversion ,
IRS ,
Multinationals ,
Required Documentation ,
Stocks ,
Tax Rates ,
Transfer Restrictions ,
U.S. Treasury