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House Releases "Tax Cuts and Jobs Act of 2017" (HR 1)

On November 2, House Ways and Means Committee Chairman Kevin Brady (R-TX) released the “Tax Cuts and Jobs Act of 2017” (HR 1, or the “Bill”). On November 3, the Chairman’s Mark of the Bill was released, and Chairman Brady...more

REIT Implications of the New “Big Six” Tax Reform Framework

On September 27, the Trump administration and the Republican leadership in the House and Senate released a document called the “Unified Framework for Fixing Our Broken Tax Code” (the “Framework”), which lays out the core...more

Energy Newsletter - September 2017

Managing Decommissioning Risks in Asian M&A Transactions - By the end of 2026, approximately 134 producing Concessions and Production Sharing Contracts (each, a “PSC”) will have expired in South Asia. It is expected that 900...more

IRS Rejects Investors' Claim for Refined Coal Credits in Technical Advice

In Technical Advice Memorandum 2017-29-020 (July 21, 2017) (the “TAM”), the IRS denied claims by two tax equity investors (the “Investors” or each an “Investor”) for renewable energy tax credits on grounds that the...more

Tax Court Overrides Key Revenue Ruling on the Tax Treatment of the Sale of U.S. Partnership Interest by Foreign Persons

In a July 13, 2017 opinion, the United States Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner refused to follow the long-held IRS position found in Revenue Ruling 91-32 (“the “Revenue...more

Tax Reform Considerations for REITs

Various components of the tax reform proposals that have been put forth by the Congress as well as the President could have significant impacts on REITs. In 2016, the Republican leadership and Republicans on the House...more

IRS and Treasury Issue Proposed Regulations Easing Some of the Burden of the Fractions Rule

Executive Summary On November 22, the Internal Revenue Service (“IRS”) and Treasury Department issued proposed regulations (REG-136978-12, the “Proposed Regulations”) under the “fractions rule” of Section 514(c)(9)(E) of the...more

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