On April 25, 2024, the IRS and Treasury issued final regulations (the “Final Regulations”) addressing whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute a...more
On December 29, 2022, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) addressing (1) whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute...more
On December 27, 2022, the IRS and Treasury issued Notice 2023-2 (the “Notice”), which provides guidance relating to the application of the new excise tax on repurchases of corporate stock (the “Stock Buyback Tax”) under...more
12/30/2022
/ De Minimus Quantity Exemption ,
Fair Market Value ,
Guidance Update ,
Internal Revenue Code (IRC) ,
IRS ,
Minority Shareholders ,
Netting Agreements ,
REIT ,
Share Buybacks ,
Shareholders ,
Special Purpose Acquisition Companies (SPACs) ,
U.S. Treasury ,
Valuation
On April 17th, the IRS and Treasury issued the next (and long-awaited) package of proposed regulations (the “Proposed Regulations”) under the “qualified opportunity zone” provisions of Section 1400Z-2 of the Code...more
4/22/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
REIT ,
Safe Harbors ,
Tax Deferral ,
U.S. Treasury
A forward sale of common shares is an offering that is agreed upon today with a settlement date in the future. Forward sale agreements allow companies to capitalize on current trading prices by locking in a price at which it...more
On September 13, 2018, the Internal Revenue Service (the “Service”) released Revenue Procedure 2018-48 (the “Revenue Procedure”), which provides guidance on how certain items of foreign-related income are treated for purposes...more
On December 22, the President signed the Tax Cuts and Jobs Act (“TCJA”) into law. TCJA changes the taxation of individuals and businesses in many ways. While there are still many open questions to be addressed by technical...more
1/15/2018
/ Capital Gains ,
Capital Investments ,
Corporate Taxes ,
Like Kind Exchanges ,
Medicare ,
Net Operating Losses ,
Pass-Through Entities ,
Popular ,
Real Estate Market ,
REIT ,
Surtax ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
UBTI
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
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