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IRS Finalizes Regulations for Domestically Controlled REITs and other Qualified Investment Entities

On April 24, 2024, the U.S. Treasury Department and the Internal Revenue Service released final regulations (the “Final Regulations”) regarding when REITs and certain regulated investment companies investing primarily in...more

New IRS and FinCEN Reporting Requirements for Businesses that Accept Payments in Digital Assets

Although the Internal Revenue Service (IRS) has postponed broker-related digital asset reporting, a less publicized requirement that applies long-standing reporting rules for physical cash payments to businesses that accept...more

New Qualified Opportunity Fund Guidance – Significant Forward Progress but Important Questions Remain Unanswered

The Treasury Department and Internal Revenue Service recently issued proposed regulations (the Proposed Regulations) and Revenue Ruling 2018-29 (the QOZ Revenue Ruling), providing much anticipated guidance for Qualified...more

New Proposed Treasury Regulations Focus on Management Fee Waivers

On July 22, 2015, the U.S. Treasury Department and Internal Revenue Service released proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code relating to disguised payments for services between partners...more

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