On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more
1/27/2021
/ Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Carried Interest Tax Rates ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Partnership Interests ,
Partnerships ,
Tax Rates ,
U.S. Treasury
On Friday, March 27, Congress passed, and the President signed, the bipartisan “Coronavirus Aid, Relief, and Economic Security Act” (the “Act”), a $2 trillion economic stimulus plan to provide funding and tax relief to...more
4/1/2020
/ Business Losses ,
CARES Act ,
Charitable Deductions ,
Coronavirus/COVID-19 ,
Employee Retention ,
Financial Stimulus ,
Income Taxes ,
Net Operating Losses ,
Payroll Taxes ,
Retirement Funds ,
Small Business ,
Student Loans ,
Tax Credits ,
Tax Deductions ,
Tax Planning ,
Tax Relief
I. Why Do REITs Have Ownership Limits in the First Place? -
Ownership limitation provisions are designed primarily to protect one of a REIT’s most valuable assets – its status as a REIT under the federal income tax...more
6/9/2016
/ Beneficial Owner ,
Board of Directors ,
Business Ownership ,
Controlling Stockholders ,
Corporate Charters ,
Income Taxes ,
Investment Management ,
Ownership Rules ,
Publicly-Traded Companies ,
REIT ,
Securities ,
Securities and Exchange Commission (SEC) ,
Tenants ,
Waivers
Under FIRPTA, a non-U.S. person’s gain from the sale of U.S. real property interests is treated as income that is effectively connected with a U.S. trade or business (“ECI”), and therefore, is subject to U.S. federal income...more