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
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
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
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
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