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IRS Issues Final Regulations on Taxation of Carried Interest Under Section 1061

On January 7, 2021, the Internal Revenue Service (the “IRS”) and the Department of the Treasury released final regulations (the “Final Regulations”) implementing the provisions of Section 1061 of the U.S. Internal Revenue...more

Land of Tax Opportunity Zones

Treasury Issues Highly Anticipated Guidance for the Implementation of Opportunity Zone Program - On October 19, 2018, the Treasury Department issued highly anticipated guidance on investment in qualified opportunity zones...more

Proposed U.S. Tax Reform May Impact Investments in U.S. Real Estate

Last week, the long-awaited proposed bill for a comprehensive reform of the U.S. tax code (the “Proposed Tax Reform”) was finally released. While the Proposed Tax Reform is likely to be heavily negotiated further and possibly...more

New Tax Court Decision Provides Planning Opportunities for Foreign Investors Investing in U.S. Partnerships

On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more

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