Introduction and Background -
Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more
8/17/2020
/ Capital Gains ,
Carried Interest ,
Economic Substance Doctrine ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
While the IRS's Proposed Regulations Are Not Yet Effective, RICs Should Carefully Consider Whether Their Portfolios or Policies Run Afoul of the New Rules.
In order for a corporation to qualify as a regulated investment...more
1/5/2017
/ Commodities ,
Controlled Foreign Corporations ,
Derivatives ,
Distribution Rules ,
Foreign Corporations ,
Investment ,
Investment Companies ,
IRS ,
Passive Foreign Investment Company ,
Qualifying Income ,
RICs ,
Securities ,
Securities and Exchange Commission (SEC)