On October 5, 2016, the Internal Revenue Service (“IRS”) and Treasury Department published final regulations (the "Final Regulations"), temporary regulations (the "Temporary Regulations") and new proposed regulations (the...more
10/25/2016
/ Business Taxes ,
Debt Financing ,
Disguised Sales ,
IRS ,
New Regulations ,
Partnership Agreements ,
Partnership Liabilities ,
Partnerships ,
Proposed Regulation ,
Risk Allocation ,
U.S. Treasury
On August 31, 2016, the Treasury Department published final regulations (the “Final Regulations”) clarifying the definition of “real property” under the real estate investment trust (“REIT”) rules. The Final Regulations...more
9/15/2016
/ Crops ,
Data Centers ,
Final Rules ,
Intangible Property ,
IRS ,
Pipelines ,
Private Letter Rulings ,
Proposed Regulation ,
REIT ,
Solar Farm ,
U.S. Treasury
On June 7, the Treasury Department released temporary regulations (the “Temporary Regulations”) that expand the types of spinoff transactions subject to the rules under Section 337(d)2 requiring gain recognition where either...more
On April 4th, the Internal Revenue Service (“IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 385 which could dramatically change how related-party indebtedness is treated for federal income tax...more
I. Overview -
On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more
8/25/2015
/ Acceleration ,
Capital Gains ,
Foreign Affiliates ,
Foreign Corporations ,
Income Taxes ,
Intangible Property ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Property Transaction Taxes ,
Reporting Requirements ,
U.S. Treasury