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IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules

The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that recharacterizes certain net long-term capital gain with...more

IRS Issues REIT-Favorable Ruling for Taxable REIT Subsidiary in Private Equity International Healthcare Acquisition

The Internal Revenue Service (IRS) ruled that a taxable real estate investment trust (REIT) subsidiary would not be considered to be operating or managing certain senior living and healthcare facilities located outside the...more

Globally (Not So) Mobile Employees: Taxation of RSU Equity Awards in a COVID-19 World

The rules relating to the US taxation of restricted stock units (RSUs) in an international context are often complex and sometimes uncertain. This On the Subject explores how COVID-19-related travel restrictions affect the US...more

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