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Tax Planning Real Estate Investment Trust Internal Revenue Service

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Provisions for the Real Estate Industry

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On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert released following the passage by the House of...more

Jones Day

The One Big Beautiful Bill Becomes Law: Key Real Estate Tax Changes

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Signed into law on July 4, 2025, the One Big Beautiful Bill Act (the "Act") permanently extends and modifies several cornerstone provisions of the Tax Cuts and Jobs Act of 2017, restores key business incentives, and makes...more

Sullivan & Worcester

Sullivan & Worcester Submits Comments to IRS Urging Caution in Applying Cloud Transaction Framework to REIT Rules

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On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more

DLA Piper

REIT Tax News - March 2025

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Welcome to the March 2025 issue of REIT Tax News. Below, we summarize five key developments impacting REITs this past quarter. Carried interest favorable taxation may be in jeopardy - On February 6, 2025, President Donald...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Morrison & Foerster LLP

Frequently Asked Questions about UPREITs and OP Unit Transactions

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

Cadwalader, Wickersham & Taft LLP

Revenue Adjusted Lease Payments Are Not REIT Qualifying Income

On February 4, 2022, the IRS released a private letter ruling revoking its prior approval of certain lease payments as “rents from real property” for purposes of the REIT income tests....more

Freeman Law

What is a REIT? Real Estate Investment Trusts and Taxation

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REITs, or real estate investment trusts, are often described as a mutual fund for real estate.  Congress established REITs to allow individual investors to invest in large-scale, income-producing real estate. Since their...more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

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Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

Stinson LLP

IRS Releases Carried Interest Proposed Regulations

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On July 31, the IRS issued proposed regulations under Section 1061 of the Internal Revenue Code further clarifying the tax treatment of carried interest and other "applicable partnership interests" (APIs)....more

Troutman Pepper Locke

Proposed Section 162(m) Regulations Affect REIT Compensation Arrangements

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Recently proposed IRS regulations reverse the reasoning of several past IRS private letter rulings regarding the application of the $1 million compensation cap of Section 162(m) to UPREIT structures in publicly traded REITs...more

Vinson & Elkins LLP

[Event] REITs: IRS Ruling Opens Door For Midstream Assets - Feb. 12th, 12:00 pm CT (and available via webcast)

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In the early 1990s, several MLPs converted into REITs to take advantage of better capital formation opportunities, but the REIT structure was not suitable for many midstream assets. Recent IRS guidance suggests this historic...more

McDermott Will & Schulte

Weekly IRS Roundup June 3 – 7, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019. June 4, 2019: The IRS issued a news release noting that it granted tax relief...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

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On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

Proskauer - Tax Talks

U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations

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On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more

A&O Shearman

Opportunity Zones: Government Issues Proposed Regulations

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On Friday, October 19, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations regarding “Qualified Opportunity Zones.” The Qualified Opportunity Zone regime was...more

McDermott Will & Schulte

Focus on Tax Strategies & Developments - December 2016

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Significant Changes in US Tax System Likely - In the short time since the surprising election of Donald J. Trump as the 45th president of the United States, much already has been written about the likelihood and likely...more

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