On April 25, 2024, the Department of the Treasury and the Internal Revenue Service issued final regulations (T.D. 9993) (the “Final Transfer Regulations”) regarding the transfer election for certain tax credits by eligible...more
On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more
As the electric vehicle (“EV”) market gains traction, real estate investment trusts (“REITs”) appear to be stepping in to alleviate a common concern of current and potential EV drivers: Where will I charge? With the demand...more
Along with the broader market, real estate investment trusts (“REITs”) and publicly traded partnerships, frequently referred to as master limited partnerships (“MLPs”), have increasingly embraced the principles of...more
9/8/2023
/ Carbon Capture and Sequestration ,
Environmental Social & Governance (ESG) ,
IRS ,
Leases ,
MLPs ,
Partnerships ,
Private Letter Rulings ,
Qualifying Income ,
Real Estate Investments ,
REIT ,
Shareholders ,
Taxable Income
In this program, attorneys in the Restructuring & Reorganization, Real Estate, Tax, and REIT Capital Markets practices discuss the various out of court considerations that commercial real estate enterprises will want to...more
5/31/2023
/ Capital Raising ,
Commercial Real Estate Market ,
Continuing Legal Education ,
Debt Restructuring ,
Disclosure Requirements ,
Events ,
Financial Distress ,
Forbearance Agreements ,
Loan Modifications ,
Popular ,
Risk Management ,
Sale of Assets
Key Takeaways-
While foreign investors are typically taxed on gain from the sale of U.S. real property interests (which include interests in most equity REITs), they are generally exempt from tax on gain from the sale of...more
Global sales of electric vehicles (“EVs”) more than doubled in 2021 over 2020, from 3 million to 6.6 million, and sales were up 60% in the first quarter of 2022 over the same period in 2021.1 With this explosive growth in the...more
Expansion of EVs and EV Charging Stations-
Electric vehicles are becoming mainstream. But are EV charging stations customary?
Historically, real estate investment trusts were intended to be passive vehicles for...more
In a ruling that may impact real estate investment trusts (REITs) with leases that have percentage or contingent rent clauses, the IRS recently changed its prior position that rent paid under a formulaic rent escalation...more
In the first REIT Series presentation of 2021, V&E tax attorneys will discuss the final carried interest regulations and their impact on REIT LTIP unit holders and real estate fund sponsors and operating partners....more
On June 4, 2020, the IRS released Notice 2020-39, which provides five key relief provisions for qualified opportunity funds (QOFs) and their investors in response to the ongoing COVID-19 pandemic:
•Extends the time period...more
On May 4, 2020, the Internal Revenue Service (“IRS”) released Revenue Procedure 2020-19, which temporarily increases to 90% the percentage of stock certain real estate investment trusts (“REITs”) may issue in an elective...more
As a result of COVID-19, the markets have been in turmoil and businesses — and thus, tenants and borrowers — have been struggling. Real estate investment trusts (“REITs”) are facing, and will continue to face, additional...more
In the early 1990s, several MLPs converted into REITs to take advantage of better capital formation opportunities, but the REIT structure was not suitable for many midstream assets. Recent IRS guidance suggests this historic...more
2/5/2020
/ Asset Management ,
Capital Formation ,
Capital Markets ,
Continuing Legal Education ,
Energy Sector ,
Equity ,
Events ,
IRS ,
Midstream Contracts ,
MLPs ,
REIT ,
Tax Planning