Seth Eaton Discusses Modifications and Workouts of Commercial Real Estate Loans during the COVID-19 Pandemic
On July 4, 2025, President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law, following the approval of Congress. OBBBA contains the following compelling updates from a real estate investment trust (REIT)...more
On July 1, 2025, a little over two weeks after the Senate Finance Committee released its draft tax title (the “Initial Senate Draft”), the U.S. Senate secured sufficient votes to advance its version of the “One Big Beautiful...more
With the tie-breaking vote cast by Vice President Vance on July 1, 2025, the Senate approved an amended version of H.R. 1, originally titled the “One Big Beautiful Bill Act,” which was previously approved by the House of...more
The past is prologue: Do REIT qualification issues close with tax years, do they persist for ten (10) years (being the sum of five (5) years on account of the Section 856(g)(3) “lock out” plus another five (5) years of...more
On May 22, 2025, the House of Representatives passed a tax bill with some limited amendments (House Tax Bill). The House Tax Bill will now head to the Senate, where additional amendments could be made. Below, we outline five...more
1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the...more
1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the world’s...more
On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of the Internal Revenue Code of...more
On Friday December 22, 2017, President Trump signed into law H.R.1, commonly referred to as the Tax Cuts and Jobs Act (TCJA). This is the most sweeping change to the U.S. federal income tax laws in over three decades, and it...more
Real estate markets in both the U.S. and Europe continue to attract significant overseas investment. With interest rates at or near all-time lows, and dwindling returns in other asset classes, real estate has emerged as...more
Despite strengthening market headwinds and troubling political uncertainties, the U.S. commercial real estate market is likely to remain the top destination for global real estate capital in 2017, and may even see a return to...more
On June 7, the Treasury Department released temporary regulations (the “Temporary Regulations”) that expand the types of spinoff transactions subject to the rules under Section 337(d)2 requiring gain recognition where either...more
In recent months, much has been written to describe the reforms to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) contained in the Protecting Americans From Tax Hikes Act of 2015 (the Act), which have been...more
On February 11, 2015, the Senate Finance Committee unanimously approved a significant reform to the Foreign Investment in Real Property Tax Act (FIRPTA). The proposal demonstrates the continued bipartisan legislative...more