News & Analysis as of September 24, 2024

Pension Funds

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

IRS Relaxes Rules for Domestically Controlled REITs

Davies Ward Phillips & Vineberg LLP on 6/20/2024

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

IRS Issues Proposed Regulations Applicable to Qualified Foreign Pension Funds and Sovereign Wealth Funds

Morgan Lewis on 1/16/2023

The Internal Revenue Service (IRS) issued proposed regulations under Sections 892 and 897 of the Internal Revenue Code of 1986, as amended, on December 29, 2022. Final regulations under Section 897 regarding the exemption...more

Weekly IRS Roundup December 26 – December 30, 2022

McDermott Will & Emery on 1/4/2023

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

Weekly IRS Roundup June 14 – June 18, 2021

McDermott Will & Emery on 6/21/2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 14, 2021 – June 18, 2021... June 14, 2021: The IRS issued a news release unveiling updates...more

Weekly IRS Roundup October 14 – October 18, 2019

McDermott Will & Emery on 10/21/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 14 – October 18, 2019. October 15, 2019: The IRS published a news release that...more

U.S. Treasury Releases Proposed FIRPTA Regulations

Jones Day on 6/13/2019

New IRS guidance issued on qualified foreign pension fund exception. On June 6, 2019, the U.S. Treasury released proposed regulations under Internal Revenue Code section 897(l) providing guidance for "qualified foreign...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

Holland & Knight LLP on 7/25/2018

• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

Real Estate Investments by Qualified Foreign Pension Funds After the PATH Act

Proskauer - Tax Talks on 3/3/2016

The Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) included a number of significant changes to the U.S. federal income tax rules related to real estate investment trusts (“REITs”) and investments by non-U.S....more

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