On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the "Act") into law. Although the individual and collective impact of the Act may not be evident for some time, the Act is generally viewed by the real...more
On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions (the “Regulations”). Many features of the Regulations had...more
On September 14, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-59 (the “Notice”) and Revenue Procedure 2015-43 (the “Rev Proc”; together with the Notice, the “Spin-Off Guidance”). Under the Spin-Off Guidance,...more
9/18/2015
/ Corporate Taxes ,
Distribution Rules ,
IRS ,
New Guidance ,
Private Letter Rulings ,
REIT ,
Revenue Procedures ,
RICs ,
Shareholders ,
Spinoffs ,
Tax-Free Transfers
On February 3, 2015, the PRC State Administration of Taxation (“SAT”) released the Announcement of SAT Concerning Several Matters Relating to Corporate Income Tax on Indirect Transfer of Properties by Non-tax Resident...more