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US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

US Department of Treasury Proposes Regulations Under Code Section 1031 That Provide Taxpayer-Friendly Guidance on Like-Kind...

Seyfarth Synopsis:  On June 12, 2020, the US Department of Treasury (the “Treasury”) promulgated proposed treasury regulations (the “Proposed Regulations”) under section 1031 (“Section 1031”) of the Internal Revenue Code of...more

CARES Act Provides Tax Relief to Real Estate Businesses

Seyfarth Synopsis: On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). The CARES Act includes federal tax provisions that should provide relief to real...more

The IRS Announces a “People First Initiative” That Will Temporarily Ease Taxpayer Payment Obligations and Postpone IRS Compliance...

Seyfarth Synopsis: On March 25, 2020, the Internal Revenue Service (“IRS”) announced its “People First Initiative” (the “Initiative”), which will provide relief to taxpayers by suspending payments under certain collection...more

Tax Reform For REITs And Real Estate Businesses

This is the third issue in a planned series of alerts designed to provide an in-depth analysis on topics related to tax reform. Background On November 2, 2017, House Republicans introduced the Tax Cuts and Jobs Act...more

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

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

Issue 99: Transition Relief for Student Health Plans and Other ACA Issues Impacting Student Employees

This is the ninety-ninth issue in our health care reform series of alerts for employers on selected topics in health care reform. This series of Health Care Reform Management Alerts is designed to provide a more in-depth...more

New Tax Law Includes Numerous Changes to REIT and FIRPTA Rules

On December 18, 2015, President Obama signed into law the “Protecting Americans from Tax Hikes Act of 2015” (the “Act”), a substantial piece of tax legislation that, among many other provisions, contains significant changes...more

Proposed Treasury Regulations Offer Guidance on Disguised Payments for Services

Fee waivers by partners for services rendered to their partnerships will now be subject to scrutiny by the Internal Revenue Service (the “IRS”), pursuant to the Treasury Department’s notice of proposed rulemaking (the...more

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