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Foreign Investment in Real Property Tax Act Investment Management Investment Funds

Paul Hastings LLP

Section 899 of the One Big Beautiful Bill — Focus on Tax and Private Funds

Paul Hastings LLP on

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

Akin Gump Strauss Hauer & Feld LLP

IRS Takes View That FIRPTA Exemption for Publicly Traded Stock Must Be Tested at Partnership Level

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

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