USA - August 24 2020
The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and JOBS Act…
Kevin Hall, Patrick J. McCurry, Alejandro Ruiz, Thomas P. Ward
USA - August 17 2020
The Internal Revenue Service (IRS) ruled that a taxable real estate investment trust (REIT) subsidiary would not be considered to be operating or…
Steven Hadjilogiou, John T. Lutz, Michael Silva
USA - October 23 2020
Section 864(c)(8) generally provides that gain or loss derived by a nonresident individual or foreign corporation from the sale or…
Ryan J. Coyle, Steven Hadjilogiou, Arianne R. Plasencia
USA - July 24 2020
On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that…
Michael J. Bruno, Le Chen, Brian H. Jenn