Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more
Key Points - Recently proposed regulations would significantly curtail the ability for private fund sponsors and non-U.S. investors to use a so-called D-REIT to facilitate a tax-efficient exit from U.S. real property...more
Readers who regularly work with deferred compensation plans will know that Section 409A of the Internal Revenue Code (“Section 409A”) prescribes six events or times at which deferred compensation may be distributed to...more
The IRS and Treasury Department issued a new and finalized version of Treasury Regulation § 301.7602-1. The regulations took effect on September 7, 2021, and shine a new light on nongovernment contractors’ participation in...more
As a result of final Treasury Regulations issued by the IRS under Section 1061, fund sponsors should consider investing capital through a commingled fund with other investors as opposed to using its own investment vehicle to...more
The U.S. Department of the Treasury has removed the United Arab Emirates from its latest "List of Countries Requiring Cooperation With an International Boycott," easing certain tax reporting requirements. On April 8, 2021,...more
Key Points - On April 8, the Treasury Department removed the UAE from its list of countries requiring cooperation with an international boycott, thereby removing the UAE from the scope of the Treasury Department’s...more
The U.S. Department of the Treasury (“Treasury”) recently published a proposed rule that would modify the mandatory filing requirements in place throughout the pilot program for certain foreign investment transactions subject...more
Final regulations relating to the determination of the foreign tax credit following the Tax Cuts and Jobs Act were released earlier this month. Though largely similar to the proposed regulations, taxpayers may be interested...more
On December 2, 2019, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued a pre-published version of final regulations (the “Final Regulations”) providing guidance with respect to...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 8 – 12, 2019. July 9, 2019: The IRS updated its frequently asked questions page for the...more