News & Analysis as of

Internal Revenue Service Internal Revenue Code (IRC) Capital Markets

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.  
Morrison & Foerster LLP

Frequently Asked Questions about UPREITs and OP Unit Transactions

A common structure for equity REITs, the UPREIT model allows a REIT to hold and operate its assets through a single operating partnership. This structure provides tax advantages and liquidity opportunities for property...more

McDermott Will & Emery

Global Equity Plan Reporting Obligations for Calendar-Year 2025: Part One

McDermott Will & Emery on

Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their...more

Holland & Knight LLP

IRS Releases Final Regulations on Reissuance and Retirement of Tax-Exempt Tender Option Bonds

Holland & Knight LLP on

The IRS released on Dec. 30, 2024, final regulations on Sections 1.150-3 and 1.1001-3(a)(2) (the Regulations) regarding the reissuance and retirement (debt extinguishment) of tax-exempt tender option bonds....more

McDermott Will & Emery

Jarrett Leaves Unanswered Questions on Taxation of Staking Rewards

McDermott Will & Emery on

In the latest turn of events for the closely followed Jarrett case concerning the taxation of staking rewards, on September 30, 2022, the US District Court for the Middle District of Tennessee granted the United States’...more

Eversheds Sutherland (US) LLP

Dividends payable partly in stock may provide capital flexibility to BDCs

The COVID-19 pandemic has caused a significant disruption in the capital markets. As a result, business development companies (BDCs) may be seeking to conserve cash in order to preserve flexibility and respond to evolving...more

Cadwalader, Wickersham & Taft LLP

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

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