Podcast: Credit Funds: Hot Topics in BDC Regulation
The U.S. Treasury finalized regulations (the “Regulations”), providing rules for public companies subject to the 1% excise tax on certain redemptions of their publicly traded stock (the “Stock Repurchase Excise Tax”). The...more
On June 28, 2024, Treasury and the IRS filed final regulations regarding the payment and reporting aspects of the stock repurchase excise tax under section 4501 of the Code1 (Buyback Tax) (Final Regulations). The Final...more
On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more
Key Takeaways- While foreign investors are typically taxed on gain from the sale of U.S. real property interests (which include interests in most equity REITs), they are generally exempt from tax on gain from the sale of...more
In this Issue. The U.S. Department of the Treasury announced that it was opening the application process for the Emergency Capital Investment Program, a new program designed to provide long-term, low-cost equity and...more
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
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
Recently-finalized, regulations provide that, in determining whether a corporation is a regulated investment company (RIC), amounts the corporation is required to include in income as a result of its investment in foreign...more
On March 19, 2019, the Internal Revenue Service (IRS) and Treasury Department (Treasury) issued final regulations (T.D. 9851) (Final Regulations) under section 851 addressing the income test applicable to regulated investment...more
In a big win for the industry, final regulations issued by the Internal Revenue Service and US Department of Treasury do not adopt all the rules set forth in the proposed regulations. Instead, regulated investment companies...more
The proposed regulations provide rules for identifying which taxpayers are subject to the BEAT and for computing BEAT liability. Key Points: The base erosion and anti-abuse tax (BEAT) proposed regulations: ...more
On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more
Last week, on October 2, 2017, the U.S. Department of the Treasury (the “Treasury”) delivered a report to President Trump that proposes substantial revisions to eight sets of controversial U.S. federal income tax regulations...more
The U.S. Department of the Treasury announced on July 7, 2017, in Notice 2017-38 (the Notice) that it has identified as "significant tax regulations" eight sets of U.S. federal tax regulations that were issued between Jan. 1,...more
The regulations affect both real estate investment trusts (REITs) and regulated investment companies (RICs) that receive appreciated property from a C corporation in a so-called “conversion transaction.”...more
The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal...more