News & Analysis as of

Real Estate Investment Trust U.S. Treasury Income Taxes

King & Spalding

Treasury Issues Final Regulations Addressing “Domestically Controlled” REIT Status

King & Spalding on

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

Proskauer - Regulatory & Compliance

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

Proskauer - Tax Talks

New Proposed Regulations Would Impact the Determination of Domestically Controlled REIT and Structures for Sovereign Wealth Funds’...

Proskauer - Tax Talks on

On December 28, 2022, the Internal Revenue Service (the “IRS”) and the Treasury Department released proposed regulations (the “Proposed Regulations”) under sections 892 and 897 of the Internal Revenue Code (the “Code”). If...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on

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

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

Jones Day on

The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more

Troutman Pepper

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper on

Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more

A&O Shearman

Opportunity Zones: Final Regulations Provide Additional Flexibility

A&O Shearman on

On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to...more

Latham & Watkins LLP

Final Section 956 Regulations Open the Door to Foreign Credit Support for US Corporate Borrowers

Latham & Watkins LLP on

Section 956 final regulations confirm those eligible for territorial dividend exemption can benefit from foreign guarantee and collateral support without incurring US tax. On May 23, 2019, the US Treasury and Internal...more

Proskauer - Tax Talks

U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations

Proskauer - Tax Talks on

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

Morrison & Foerster LLP

Treasury Report Proposes Substantial Revisions to Controversial Tax Regulations

Morrison & Foerster LLP on

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

McDermott Will & Emery

Final Regulations Define “Real Property” for REITs: Considerations for Renewable Energy and Transmission Assets

McDermott Will & Emery on

The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided. ...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

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Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

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