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Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Post Election – Expect Tax Legislation

With clear Republican victories in the White House and the Senate, and a very slim majority for either side in the House of Representatives, we can expect tax legislation in the coming year. It is expected that the President...more

No Money? No Problem: Recent IRS Favorable Guidance Regarding a REIT’s First Year

On October 4, 2024, the Internal Revenue Service (the “IRS”) released Private Letter Ruling 202440007, which concluded that the lack of income and assets in the first taxable year of an entity that had elected to be treated...more

The IRS and Senator Warren Raise Concerns about Lodging and Health Care REITs

On September 3, 2024, Senator Elizabeth Warren (D-MA) sent a letter to the Internal Revenue Service (the “IRS”) urging it to “increase enforcement scrutiny of REITs, especially large health and hospitality REITs that may be...more

Final Regulations on Domestically Controlled REITs

On April 24, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued final regulations on the definition of “domestically controlled” real estate investment trusts (“REITs”)...more

IRS and Treasury Provide Guidance on the Excise Tax on Repurchases of Corporate Stock under Section 4501

On December 27, 2022, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) released Notice 2023-2 (the “Notice”), which provides guidance regarding the application of the 1% excise tax...more

Summary of the Biden Administration’s Fiscal Year 2023 Green Book Tax Proposals

On March 28, 2022, the Biden Administration released the Fiscal Year 2023 Budget, and the “General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals,” which is commonly referred to as the “Green Book.” ...more

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