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Morrison & Foerster LLP

Frequently Asked Questions about UPREITs and OP Unit Transactions

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A common structure for equity REITs, the UPREIT model allows a REIT to hold and operate its assets through a single operating partnership. This structure provides tax advantages and liquidity opportunities for property...more

Levenfeld Pearlstein, LLC

PTET in Private Equity Accounting Deals in 2025 and Beyond?

Levenfeld Pearlstein, LLC on

In connection with the first Trump administration’s tax bill known as the Tax Cuts and Jobs Act (“Jobs Act”), a cap on state and local tax deductions was instituted at $10,000 (“SALT Cap”) for tax years 2018 through 2025. The...more

McDermott Will & Emery

Global Equity Plan Reporting Obligations for Calendar-Year 2025: Part One

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Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their...more

Holland & Knight LLP

IRS Releases Final Regulations on Reissuance and Retirement of Tax-Exempt Tender Option Bonds

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The IRS released on Dec. 30, 2024, final regulations on Sections 1.150-3 and 1.1001-3(a)(2) (the Regulations) regarding the reissuance and retirement (debt extinguishment) of tax-exempt tender option bonds....more

Crunched Credit

Time to Fix REMIC:  Grand Bargain Part II

Crunched Credit on

Last week I talked about the Grand Bargain to fix our business. If we’re fixing to fix our business now, we’ve got to talk REMIC. The Real Estate Mortgage Investment Conduit (REMIC) created as part of the Tax Reform Act of...more

McDermott Will & Emery

Jarrett Leaves Unanswered Questions on Taxation of Staking Rewards

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In the latest turn of events for the closely followed Jarrett case concerning the taxation of staking rewards, on September 30, 2022, the US District Court for the Middle District of Tennessee granted the United States’...more

Foley & Lardner LLP

Reading the Leaves: What's in Store for Cannabis in 2021

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On the heels of a year beset by turmoil and the myriad challenges caused by the global pandemic, the cannabis industry nevertheless entered 2021 poised for significant growth amid a landscape teeming with opportunity. Public...more

Eversheds Sutherland (US) LLP

Dividends payable partly in stock may provide capital flexibility to BDCs

Eversheds Sutherland (US) LLP on

The COVID-19 pandemic has caused a significant disruption in the capital markets. As a result, business development companies (BDCs) may be seeking to conserve cash in order to preserve flexibility and respond to evolving...more

WilmerHale

2016 IPO Report

WilmerHale on

Our 2016 IPO Report offers a detailed analysis of, and outlook for, the IPO market, plus useful IPO market metrics. We look at rates of adoption of JOBS Act relief by emerging growth companies, and recent FAST Act amendments...more

Cadwalader, Wickersham & Taft LLP

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

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On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

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