The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) have recently issued final regulations (the “Final Regulations”) that significantly impact the determination of whether a real...more
The treatment of contingent interest and convertible debt in cross-border payment transactions is subject to several provisions of the Internal Revenue Code. To add confusion to the already complicated subject, the...more
On December 29, 2022 the IRS and the Treasury Department issued a notice of proposed rulemaking (REG-100442-22) (the “Proposed Regulations”) that, among other things, affects the determination when Real Estate Investment...more
3/3/2023
/ Financial Services Industry ,
FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Mortgage REITS ,
Proposed Regulation ,
Real Estate Investments ,
Real Estate Market ,
REIT ,
Tax Liability