Jeffrey DeBoer on the intersection of Washington and commercial real estate
On May 22, the House of Representatives voted to approve the One Big Beautiful Bill (OB3), which contains a new addition to the U.S. Internal Revenue Code — Section 899. OB3 is now under consideration by the Senate, which...more
Key Points Internal IRS correspondence in the form of a recent Chief Counsel Memorandum concludes that funds structured as partnerships (e.g., master funds in a standard master-feeder structure) must determine the...more
The US Department of Treasury recently released final regulations providing guidance on the exception from taxation under the Foreign Investment in Real Property Tax Act of 1980 for “qualified foreign pension funds” under...more
Hedge Funds and Taxes - Hedge funds provide a vehicle to pool private capital for investment in stocks, securities and financial derivatives. While hedge funds take on many different structures—including master-feeder,...more