Seth Eaton Discusses Modifications and Workouts of Commercial Real Estate Loans during the COVID-19 Pandemic
On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more
The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) have recently issued final regulations (the “Final Regulations”) that significantly impact the determination of whether a real...more
On April 25, 2024, the IRS and Treasury issued final regulations (the “Final Regulations”) addressing whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute a...more
On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the...more
The United States Department of Treasury issued final regulations (Final Regulations) that arguably change the test (DC Test) for determining whether a REIT is a domestically controlled qualified investment entity (DC-REIT)....more
On April 24, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (IRS) released final regulations (“Final Regulations”) under Section 897 of the Internal Revenue Code of 1986, as amended, addressing...more
On December 29, 2022, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) addressing (1) whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute...more
The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more
On December 28, 2022, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) on the treatment of qualified foreign pension funds (“QFPFs”) for purposes of the exemption from taxation for...more
Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more
On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more
The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more
As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...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
On June 7, the Treasury Department released temporary regulations (the “Temporary Regulations”) that expand the types of spinoff transactions subject to the rules under Section 337(d)2 requiring gain recognition where either...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 Treasury Department today released new temporary and proposed regulations that will impact spinoffs and REIT conversions and modify the definition of “converted property” with respect to REIT transactions....more
On May 9, 2014, the Internal Revenue Service and U.S. Department of the Treasury issued proposed regulations (the Proposed Regulations) under Section 856 of the Internal Revenue Code (the Code) to clarify the definition of...more