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DST Bridge Lending - Considerations for the Borrower, Senior Lender, and Bridge Lender

Broadly syndicated Section 1031 investment programs, such as DSTs and TICs, have been popular with a growing number of real estate investors since the early 2000s due to their ability to allow investors to reinvest in...more

Relief at Last for Qualified Opportunity Zone Businesses with Pre-Pandemic Working Capital Safe Harbor Plans

Seyfarth Synopsis: On April 12, 2021, the Department of Treasury (“Treasury”) published proposed Treasury regulations (the “Proposed Regulations”) that (1) permit qualified opportunity zone businesses (“QOZBs”) to revise or...more

IRS Extends Prior Relief to Opportunity Zone Investment Programs

Seyfarth Synopsis: On January 19, 2021, the Internal Revenue Service (the “IRS”) issued Notice 2021-10 (the “Notice”), which extends the relief that it previously provided to qualified opportunity funds, their sponsors, and...more

The Internal Revenue Service Extends the Payment Period for Certain Deferred Employee Payroll Taxes in Accordance with Recently...

Seyfarth Synopsis: On January 19, 2021, the Internal Revenue Service (“IRS”) issued guidance (the “Guidance”) in accordance with the recently enacted COVID-related Tax Relief Act of 2020 (the “Act”) extending the payment...more

Questions Remain After Treasury Guidance Implementing President Trump’s Payroll Tax Deferral

Seyfarth Synopsis: On August 28, 2020, the Internal Revenue Service (“IRS”) issued guidance (the “Guidance”) to implement the payroll tax withholding and payment deferral provided for in President Trump’s Presidential...more

President Trump Signs Four Executive Orders Providing or Extending Coronavirus Relief

Seyfarth Synopsis: On August 8, 2020, President Trump issued an Executive Order and three Memoranda to his Cabinet and Executive Agency heads (collectively, the “Executive Orders”) that provide or extend COVID-19 relief to...more

US Department of Treasury Proposes Regulations Under Code Section 1031 That Provide Taxpayer-Friendly Guidance on Like-Kind...

Seyfarth Synopsis:  On June 12, 2020, the US Department of Treasury (the “Treasury”) promulgated proposed treasury regulations (the “Proposed Regulations”) under section 1031 (“Section 1031”) of the Internal Revenue Code of...more

IRS Provides Relief to Opportunity Zone Investment Programs

In Notice 2020-39, issued on Thursday, June 4, 2020, the IRS made substantial accommodations to Qualified Opportunity Funds, and their sponsors and investors, to allow them to address the challenges presented by COVID-19....more

The IRS Extends Filing and Payment Obligations for Most Taxpayers and Performance of Certain Taxpayer Time-Sensitive Actions Until...

On April 9, 2020, the Secretary of the U.S. Department of Treasury (the “Secretary”) and the Internal Revenue Service (the “IRS”) issued Notice 2020-23 (the “Notice”), which extends the deadline for performance of a long list...more

The IRS Extends the 45-Day and 180-Day Deadlines for Section 1031 Exchanges Initiated Before March 13, 2020 and the Deadline to...

On April 9, 2020, following issuance by the President of the United States of an emergency declaration under the Robert T. Stafford Disaster Relief and Emergency Assistance Act on March 13, 2020, the Secretary of the U.S....more

CARES Act Provides Tax Relief to Real Estate Businesses

Seyfarth Synopsis: On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). The CARES Act includes federal tax provisions that should provide relief to real...more

Final Regulations Clarify and Liberalize Many Rules Governing Qualified Opportunity Fund Formation and Operations

Seyfarth Synopsis: On December 19, 2019, the U.S. Treasury issued final Qualified Opportunity Zone regulations (the “Final QOZ Regulations”). Subject to the commentary in the Preamble to the Final QOZ Regulations on circular...more

Tax Reform For REITs And Real Estate Businesses

This is the third issue in a planned series of alerts designed to provide an in-depth analysis on topics related to tax reform. Background On November 2, 2017, House Republicans introduced the Tax Cuts and Jobs Act...more

One Step Back, One Step Forward: New Debt-Equity Regulations Narrow Their Focus on Earnings Stripping

Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more

There is life after death...of the Bottom-Dollar Guarantee

Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more

New Tax Law Includes Numerous Changes to REIT and FIRPTA Rules

On December 18, 2015, President Obama signed into law the “Protecting Americans from Tax Hikes Act of 2015” (the “Act”), a substantial piece of tax legislation that, among many other provisions, contains significant changes...more

Causation In Federal Remedial Rights And Alternative Pleading

Several recent Supreme Court decisions have upended causation standards in the statutory alphabet soup of federal remedial rights. It is now clear that “but for” causation governs discrimination claims under the Age...more

Effective Carve-Outs to Seek Injunctive Relief from the Court in Arbitration Provisions

Christopher Pike: “That’s a technicality.” Spock: “I am a [lawyer], sir. We embrace technicalities.” Star Trek Into Darkness - Arbitration is no longer the final frontier. Instead, arbitration is often the...more

Proposed Treasury Regulations Offer Guidance on Disguised Payments for Services

Fee waivers by partners for services rendered to their partnerships will now be subject to scrutiny by the Internal Revenue Service (the “IRS”), pursuant to the Treasury Department’s notice of proposed rulemaking (the...more

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