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Internal Revenue Service Diversification Requirements

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Freeman Law

Transfers of Stock or Securities to Investment Partnerships: A Dangerous Exception Lurking for the Unwary

Freeman Law on

The formation of a partnership is generally a nonrecognition transaction for both the contributing partner and the newly created firm. Thus, no gain is recognized to a partnership or to any of its partners because of a...more

Eversheds Sutherland (US) LLP

IRS provides IRC § 817(h) diversification guidance on a new form of mortgage-backed security to be issued by Fannie Mae and...

On October 16, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-54, which addresses the treatment of a new mortgage-backed security under the diversification rules of IRC § 817(h). This new security, called a...more

Coblentz Patch Duffy & Bass

Investing Private Foundation Assets: What Every Foundation Manager Should Know

Those responsible for managing a private foundation’s investment assets may not always understand the unique fiduciary and tax constraints imposed on private foundations and their managers by both state and federal law....more

Morgan Lewis

IRS Offers Tax Guidance Relating to Money Market Fund Rules

Morgan Lewis on

The IRS recently provided relief from the RIC distribution requirement for money market funds that receive contributions in connection with the transition to a floating NAV, enabling RICs to top up their NAVs without having...more

Eversheds Sutherland (US) LLP

IRS Notice Offers Relief to Issuers of Variable Insurance Products in Response to Pending Money Market Fund Reforms

On May 5, 2016, the IRS issued Notice 2016-32, 2016-21 I.R.B. 1, which affords relief with respect to the application of the diversification requirements of IRC § 817(h) to variable life insurance and annuity contracts...more

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