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Final Regulations Issued on Domestically Controlled REIT Determinations and Energy Credit Transfers

Two sets of recently finalized regulations provide guidance for REITs. Key Points: - Final FIRPTA regulations provide rules for determining whether a REIT is domestically controlled, including a look-through rule for...more

Considerations for REITs in Adopting a Poison Pill in Response to the COVID-19 Crisis

REIT management and boards of directors should review their defensive profile and consider whether to prepare a rights plan. Key Points: ..Unprecedented market volatility and investor uncertainty due to the coronavirus...more

IRS Relaxes Stock Dividend Safe Harbor for Publicly Offered REITs and RICs in 2020

Recent IRS guidance reduces the minimum aggregate amount of cash required for certain distributions of stock and cash to qualify for the dividends paid deduction. In order to enhance liquidity of publicly offered real...more

Spin-offs Unraveled: Complex ‘IPOs’ With a Sophisticated Tax Overlay - Key Considerations When Spinning Off a Business Segment or...

In a spin-off, a public company separates one or more of its businesses into new, publicly traded companies. For the public company that initiates it, a spin-off can achieve a number of critical business and financial...more

IRS Publishes Ruling Requirements for Certain Tax-Free Spin-Off Monetization Transactions

The new guidance is significant given the popularity of debt exchanges as a monetization technique in conjunction with spin-offs. On October 3, 2018, the Internal Revenue Service (IRS) published Revenue Procedure 2018-53,...more

IRS Studying Active Trade or Business Requirement for Tax-Free Spin-Offs

The IRS is considering future guidance that could present opportunities for R&D phase businesses. In a statement issued on September 25, 2018, the Internal Revenue Service (IRS) announced that it is studying the active...more

IRS Provides Guidance on Stock Distributions for Publicly Offered REITs and RICs

Revenue procedure sets forth requirements for ensuring certain stock distributions are treated as property distributions eligible for dividends paid deduction. On August 11, 2017, the Internal Revenue Service (IRS)...more

IRS Tightens Rules on Disguised Sales and Allocating Partnership Liabilities

New final, temporary and proposed regulations address leveraged transactions, “bottom-dollar” guarantees and other issues, but postpone action on some key questions. On October 4, 2016, the Internal Revenue Service (IRS)...more

Congress Enacts Significant Changes to the REIT and FIRPTA Rules

Changes include restrictions on tax-free REIT spinoffs and other reforms generally favorable to REITs and non-US investors in US real estate. On December 18, 2015, President Obama signed into law the Protecting Americans...more

IRS Adds Certain Spin Transactions to the “No Rule” List

Treasury and IRS announce that certain “cash rich” and REIT/RIC conversion spin-offs are under study and are added to the “no rule” list. On September 14, 2015, the United States Treasury Department (the Treasury) and...more

10/1/2015  /  IRS , REIT , RICs , Shareholders , Spinoffs , U.S. Treasury
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