Seth Eaton Discusses Modifications and Workouts of Commercial Real Estate Loans during the COVID-19 Pandemic
On 9 July 2025, the Capital Market Authority (the “CMA”) has announced a series of significant regulatory enhancements aimed at furthering the development of the Kingdom’s investment fund industry. These amendments, effective...more
President Donald J. Trump signed the legislation commonly known as the “One Big Beautiful Bill” (Tax Act) into law on July 4, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management...more
This Memorandum continues our analysis of the current U.S. federal tax reform process. Today, the House of Representative passed the Senate’s version of the One Big, Beautiful Bill (the “Senate Tax Bill”). The Senate Tax Bill...more
The Financial Stability Board (FSB) has published a report, alongside a press release and updated webpage, examining vulnerabilities in non-bank commercial real estate (CRE) investors. The report identifies entities such as...more
The US Senate released a draft tax bill (Senate Tax Bill) on June 16, 2025. We explore five key takeaways for fund sponsors, investors, and the broader asset management community, with a focus on how the Senate Tax Bill...more
It seems like such a simple question. Who owns data centers? Ownership structures in the digital economy are more varied than might appear on the surface. While the largest computing and cloud service providers, such as...more
On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more
On May 14, 2025, the House Ways and Means Committee approved the so-called “One Big Beautiful Bill” (Bill). We have issued several other alerts regarding the Bill. Among other tax provisions, the Bill includes two provisions...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
On May 9, 2025, House Committee on Ways and Means Chairman Jason Smith (R-MO) released a proposed 28-page tax bill, which is scheduled for markup by the House Committee on Ways and Means on May 13, 2025. Below, we highlight...more
The growth of the operational real estate (OpRE) sector is one of the most significant recent trends in global real estate markets. OpRE is relevant to a wide range of real estate asset classes and subsectors, but all OpRE...more
Guernsey has long been one of the world's premier jurisdictions for investment funds - There are a number of advantages for using Guernsey as a jurisdiction, including the wide variety of company and limited partnership...more
In our 2022 alert “REIT M&A Trends Through the Pandemic,” we cataloged a total of 42 new REIT transactions announced between August 2020 and May 2022, a pace that rivaled or exceeded pre-pandemic levels. From May 2022 through...more
UK real estate investment trusts (UK REITs) benefit from certain tax exemptions that have the effect of putting their shareholders in a tax position broadly equivalent to that of a direct investor in UK real estate. Those...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
Watch the full recording. What Is the CTA? The CTA (31 USC § 5336; 31 CFR 1010) is intended to strengthen the federal government’s anti-money laundering efforts by requiring many business entities to report information...more
Underneath the headline points, the Budget contained a number of measures designed to fulfil the Chancellor’s objective of encouraging growth and investment. There was broadly good news for those investing in UK real estate....more
Amongst the usual round of rate changes and technical measures (including replacement of the capital allowances “super-deduction” regime with full expensing for companies incurring expenditure on plant and machinery over 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
These days, we seem to be surrounded by cautionary forecasts. For example, in a recent post about U.S. REITs, Fitch Ratings indicated that it expects to see slower growth in the sectors that have been growing, and additional...more
PROPOSAL FORECASTS GREATER REGULATION OF ALTERNATIVE ASSETS - On July 12, 2022, the North American Securities Administrators Association, Inc. (“NASAA”), an organization representing state securities regulators, released a...more
It was a relatively light Budget for the real estate sector. Highlights included the long-awaited announcement of the rate of the residential property developer tax and some reform of business rates....more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
At our recent Funds First webinar we shared some technical and market issues and updates on a selection of key developments of impact for real estate funds. Our discussion covered the Long Term Asset Fund (LTAF) , the...more
As part of its March 2020 Budget, the UK government announced that it would undertake a review of the UK’s funds regime. Since then, the UK government has gone on to publish a series of consultations and documents, committing...more