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Akin Gump Strauss Hauer & Feld LLP

The Health Over Wealth Act Takes Aim at Private Equity Investment in Health Care

Key Points - Congress is increasing oversight and legislative activity related to the role of private equity in health care. Sen. Markey and Rep. Jayapal jointly introduced the Health Over Wealth Act on July 25, which aims to...more

Eversheds Sutherland (US) LLP

Treasury and the IRS issue final regulations addressing the payment and reporting of the stock buyback tax

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

Vinson & Elkins LLP

Considerations for REITs, their Subsidiaries, and Other Real Estate Companies under the Corporate Transparency Act

Vinson & Elkins LLP on

The Corporate Transparency Act (the “CTA”), a new federal law, went into effect on January 1, 2024. The CTA requires that certain entities file Beneficial Ownership Information Reports (“BOI Reports”) with the Financial...more

Morrison & Foerster LLP

Who Owns and Controls Your Real Estate Entity? FinCEN Wants to Know, and its Final Rule is now in Effect

This client alert is an update to an earlier MoFo client alert issued on December 8, 2022. In a final rule implementing the Corporate Transparency Act (the “Final Rule”), the Financial Crimes Enforcement Network (“FinCEN”)...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

Arnall Golden Gregory LLP

Proposed Rule Highlights Continued Push by CMS for Skilled Nursing Facility Ownership Transparency

In recent years, the Biden administration and Congress have pushed for greater transparency in skilled nursing facility ownership. In an effort focused on increased ownership disclosures specifically related to private equity...more

McDermott Will & Emery

Biden Administration and CMS Propose New Rule to Provide Greater Transparency for Nursing Home Ownership

McDermott Will & Emery on

Following the Biden administration’s efforts to promote nursing home safety, transparency, accountability and quality, the US Centers for Medicare & Medicaid Services (CMS) announced a proposed rule governing nursing home...more

Morrison & Foerster LLP

Who Owns and Controls Your Real Estate Entity? FinCEN Wants to Know

Under a final rule (the “Final Rule”) recently issued by the Financial Crimes Enforcement Network (“FinCEN”), beginning January 1, 2024, entities that own and operate U.S. real estate must report their “Beneficial Owners”—the...more

Dechert LLP

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers (UPDATED)

Dechert LLP on

In March 2022, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of U.S. ownership of foreign securities....more

Whitman Legal Solutions, LLC

Corporate Transparency Act–What Real Estate Sponsors and Investors Should Do Now to Prepare

Businesses facing a new law or regulation are like orchestra musicians. Most businesses will plan ahead so they can comply with new legal requirements on the law’s effective date. However, some laws are general and...more

ArentFox Schiff

Cannabis REIT Securities Filing Demonstrates How to Disclose the Regulatory Risks of Funding Cannabis Ventures to Investors

ArentFox Schiff on

AFC Gamma’s SEC filing illustrates the importance of proper risk assessment and adequate risk factor disclosures to investors in the rapidly-shifting regulatory landscape of cannabis production, sales, and lending. AFC...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

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

White & Case LLP on

On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Proskauer - Tax Talks

The Second Set of Proposed Opportunity Zone Regulations

Proskauer - Tax Talks on

Introduction - On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more

Dechert LLP

U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers

Dechert LLP on

TIC SHC is a mandatory benchmark study commissioned by the Treasury and administered by the FRBNY every five years.3 The survey reviews holdings of foreign portfolio securities – including short- and long-term securities and...more

Dechert LLP

New Treasury Regulations Curtail Planning Opportunities for Partnership Structures

Dechert LLP on

The U.S. Treasury Department and the Internal Revenue Service issued final and temporary regulations (the “2016 Regulations”) on October 5, 2016 addressing the partnership disguised sale and debt allocation rules. The 2016...more

Seyfarth Shaw LLP

There is life after death...of the Bottom-Dollar Guarantee

Seyfarth Shaw LLP on

Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Morrison & Foerster LLP

Tax Talk -- Volume 7, No. 2 -- July 2014

In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more

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