The U.S. Internal Revenue Service (“IRS”), on August 11, 2017, issued Revenue Procedure 2017-45 (the “New Revenue Procedure”).1 Pursuant to the New Revenue Procedure, the IRS will treat part cash and part stock distributions...more
The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more
10/26/2016
/ Capital Expenditures ,
Debt ,
Debt Financing ,
Disguised Sales ,
Final Rules ,
IRS ,
Partnerships ,
Proposed Regulation ,
REIT ,
Reporting Requirements ,
Risk Allocation ,
Tax Structuring ,
U.S. Treasury