The Internal Revenue Service announces forthcoming regulations in relation to “ECI withholding” under Section 1446(f). It also announces interim relief and guidance for taxpayers pending regulations....more
New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions.
On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more
The final, temporary, and proposed regulations issued by the Internal Revenue Service on October 13 relating to intercompany debt obligations between members of an affiliated group of corporations under Section 385 of the...more
11/3/2016
/ Collateralized Debt Obligations ,
Corporate Counsel ,
Foreign Corporations ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Multinationals ,
Parent Corporation ,
Private Equity ,
Proposed Regulation ,
Registered Investment Companies (RICs) ,
REIT ,
S-Corporation ,
Section 385 ,
Stocks
The PATH Act exempts certain foreign pension funds from taxation under FIRPTA and significantly modifies the tax rules applicable to REITs.
On December 18, 2015 (Enactment Date), US President Barack Obama signed the...more
1/6/2016
/ FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Pension Funds ,
Protecting Americans from Tax Hikes (PATH) Act ,
Real Estate Investments ,
Registered Investment Companies (RICs) ,
REIT ,
Securities and Exchange Commission (SEC) ,
Shareholders ,
Spinoffs
The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more
7/28/2015
/ Enterprise Risks ,
Fee Waivers ,
Internal Revenue Code (IRC) ,
Intra-Group Transactions ,
Investment Management ,
IRS ,
Management Fees ,
Proposed Regulation ,
Safe Harbors ,
Taxable Distributions ,
U.S. Treasury