As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more
4/24/2019
/ Anti-Abuse Rule ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Transactions ,
S-Corporation ,
Safe Harbors ,
Tangible Property ,
U.S. Treasury
On October 31, the Internal Revenue Service (IRS) released proposed regulations (the "Proposed Regulations") under Section 956 that could substantially increase the collateral packages made available by US corporate borrowers...more
11/6/2018
/ Controlled Foreign Corporations ,
Corporate Financing ,
Dividends ,
Domestic Corporations ,
GILTI tax ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Section 956 ,
Shareholders ,
Subsidiaries ,
U.S. Treasury
On October 19, the Internal Revenue Service (IRS) and US Department of the Treasury released the first set of proposed regulations under Internal Revenue Code Subchapter Z—Opportunity Zones (Proposed Regulations). On the same...more
10/23/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Planning ,
U.S. Treasury