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Capital Gains Real Estate Investment Trust

Ankura

Tax Liability Insurance - M&A and Beyond

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During the diligence phase of a transaction, it is not uncommon for a buyer to identify potential tax liabilities that may be caused by a number of situations: uncertainty over a tax structure, an estimated fair market value...more

Davies Ward Phillips & Vineberg LLP

IRS Relaxes Rules for Domestically Controlled REITs

Non-U.S. investors are generally subject to U.S. federal income tax on gains from investments in private U.S. real estate investment trusts (REITs). Two exceptions (among others) are for investments in “domestically...more

Skadden, Arps, Slate, Meagher & Flom LLP

Activists Assemble: Recent Trends in Activist Campaigns Targeting UK Investment Trusts

The United Kingdom has long been a target destination for activist investors. It is the venue for nearly half of all of recent activist campaigns in Europe. In previous articles, we have discussed how informed boards should...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more

BCLP

Tax changes to Luxembourg structures investing in UK real estate

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The UK and Luxembourg have renegotiated their double tax treaty. The new treaty has been published, but is not yet in force. Significant changes have been made to the capital gains tax article amongst other provisions....more

BCLP

Impact of UK Autumn Budget on real estate sector

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It was a relatively light Budget for the real estate sector. Highlights included the long-awaited announcement of the rate of the residential property developer tax and some reform of business rates....more

McDermott Will & Emery

What Is a QOF?

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Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

ArentFox Schiff

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

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The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more

Williams Mullen

IRS Releases Finalized Regulations Regarding Taxation of Carried Interest

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The U.S. Department of Treasury and the Internal Revenue Service recently issued final regulations (“the Final Regulations”) regarding certain aspects of so-called carried interest under Section 1061 of the Internal Revenue...more

Mayer Brown Free Writings + Perspectives

On point. – Real Estate Investment Trusts (REITs)

Real estate investment trusts (“REITs”) are professionally managed companies that invest in real estate, mortgages and real estaterelated assets on behalf of their investors. Established in 1960, REITs were designed to...more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

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Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

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The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more

Troutman Pepper

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

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Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

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On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Dechert LLP

Proposed Carried Interest Regulations: Treasury Carries the Ball, Giving Precious Few Points to Fund Managers

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The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more

Stinson LLP

IRS Releases Carried Interest Proposed Regulations

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On July 31, the IRS issued proposed regulations under Section 1061 of the Internal Revenue Code further clarifying the tax treatment of carried interest and other "applicable partnership interests" (APIs)....more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

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On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

Vinson & Elkins LLP

REIT-Specific Tax Considerations In The COVID-19 Era

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As a result of COVID-19, the markets have been in turmoil and businesses — and thus, tenants and borrowers — have been struggling. Real estate investment trusts (“REITs”) are facing, and will continue to face, additional...more

Akerman LLP

Treasury And IRS Issue Final Opportunity Zone Tax Regulations

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On December 19, 2019, the Treasury and the IRS fulfilled their promise to issue final regulations by year-end that provide guidance on Qualified Opportunity Zone (QOZ) investments. These regulations (the Final Regulations),...more

A&O Shearman

Opportunity Zones: Final Regulations Provide Additional Flexibility

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On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to...more

Shumaker, Loop & Kendrick, LLP

Client Alert: End of Year Deadline for Opportunity Zone Investments

The Tax Cuts & Jobs Act (TCJA) created Opportunity Zones (“OZ”) which offer investors the chance to defer and eliminate capital gains based on investments in designated zones that meet certain requirements and hit specified...more

Whitman Legal Solutions, LLC

Leaving a String Quartet or Tenant-in-Common Real Estate Investment

The Cleveland Quartet musicians had the luxury of selecting the time when they wanted to disband. They also likely didn’t have to think about tax consequences when they disbanded.   However, for individuals who jointly...more

Goulston & Storrs PC

Qualified Opportunity Zones: New Proposed Regulations Provide Further Guidance

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The Treasury Department has now released a second round of proposed regulations on the Qualified Opportunity Zone (“QOZ”) provisions under Internal Revenue Code Section 1400Z-2....more

Proskauer - Tax Talks

The Second Set of Proposed Opportunity Zone Regulations

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Introduction - On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more

Verrill

Opportunity Fund Investors Prepare to Zone-In

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Treasury Provides Additional Clarity on Opportunity Zones by Issuing Second Round of Proposed Regulations - On April 17, 2019, the U.S. Department of the Treasury issued its second set of proposed regulations (the “New...more

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