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Part Cash, Part Stock, 100 Taxable - New IRS Guidance on RIC and REIT Distributions

USA - August 25 2017 The U.S. Internal Revenue Service ("IRS"), on August 11, 2017, issued Revenue Procedure 2017-45 (the "New Revenue Procedure").1 Pursuant to the New...

Jay Buchman, Ari M. Zak, Steven E. Clemens.

IRS Issues Proposed Regulations Relating to the Treatment by Regulated Investment Companies of Income from Subsidiaries Investing in Commodities

USA - November 4 2016 The IRS has recently issued Proposed Regulations under Section 851(b) of the Internal Revenue Code (the “Proposed Regulations”), and a Revenue...

Jay Buchman, Ari M. Zak, Richard M. Hervey, Daniel M. Dunn.

IRS Issues Proposed Regulations Relating to the Treatment by Regulated Investment Companies of Income from Subsidiaries Investing in Commodities

USA - November 4 2016 The IRS has recently issued Proposed Regulations1 under Section 851(b) of the Internal Revenue Code2 (the "Proposed Regulations"), and a Revenue...

Jay Buchman, Ari M. Zak, Richard M. Hervey, Daniel M. Dunn.

Tax Considerations for BDC Consolidation Transactions

USA - July 27 2016 Interest in consolidating Business Development Companies (BDCs) has been significant attention during the past several quarters. Some reasons for...

Final US Treasury Regulations Provide Additional Flexibility in Determining the Tax Implications of Money Market Fund Share Transactions

USA - July 25 2016 Final U.S. Treasury regulations under Section 446 of the Internal Revenue Code of 1986, as amended (the "Code'), providing for the use of the net...

Jay Buchman, Ari M. Zak, Richard M. Hervey.