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
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