With the tie-breaking vote cast by Vice President Vance on July 1, 2025, the Senate approved an amended version of H.R. 1, originally titled the “One Big Beautiful Bill Act,” which was previously approved by the House of...more
7/8/2025
/ Clean Energy ,
Corporate Taxes ,
Energy Tax Incentives ,
Federal Budget ,
Federal Funding ,
Investment Tax Credits ,
Legislative Agendas ,
New Legislation ,
Real Estate Investments ,
REIT ,
Tax Deductions ,
Tax Incentives ,
Tax Reform
On June 16, 2025, the U.S. Senate Finance Committee released its version (the “Senate Bill”) of the “One Big Beautiful Bill Act” passed by the U.S. House of Representatives on May 22, 2025 (the "House Bill”). This alert...more
On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more
6/13/2025
/ Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
Proposed Rules ,
Real Estate Investments ,
Regulatory Agencies ,
REIT ,
Statutory Interpretation ,
Tax Liability ,
Tax Planning ,
Treasury Regulations
The past is prologue: Do REIT qualification issues close with tax years, do they persist for ten (10) years (being the sum of five (5) years on account of the Section 856(g)(3) “lock out” plus another five (5) years of...more
6/4/2025
/ Acquisitions ,
Corporate Taxes ,
Due Diligence ,
Internal Revenue Code (IRC) ,
Mergers ,
Real Estate Investments ,
REIT ,
Remediation ,
Tax Liability ,
Tax Planning ,
Taxation
The U.S. House of Representatives, by a one-vote margin, passed the “One Big Beautiful Bill Act” (the “House Bill”) early in the morning on May 22, 2025. The House Bill has yet to be considered by the U.S. Senate and will...more
5/29/2025
/ Business Taxes ,
Commercial Real Estate Market ,
Corporate Taxes ,
EBITDA ,
Energy Sector ,
Federal Budget ,
Foreign Tax ,
Income Taxes ,
New Legislation ,
Proposed Legislation ,
REIT ,
Tax Credits ,
Tax Deductions ,
Tax Reform
On April 16, 2024, Ameek Ashok Ponda, with assistance from Paul Decker, Sarah Wellings and Connie Lee, submitted a comment letter to the Internal Revenue Service (IRS) regarding his recommendations for the 2024-2025 Priority...more
When Treasury promulgated Treasury Decision 9784, I.R.B 2016-39 nearly a decade ago, the net metering renewable energy safe harbor (Section XI “Renewable Energy”, Subsection A) was welcome guidance that was fit for the time...more
The ORIAD: How to be a REIT (Sections 856-860)
- Organization
- Rents from real property
- Income from passive sources
- Assets that are real property and real estate assets, and are not excessive securities
-...more