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
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
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