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“Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

USA - June 29 2020 On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final…

Amanda H Nussbaum, Christine N. Younger, Malcolm Hochenberg, Martin T Hamilton, Martine Seiden Agatston, Stuart L Rosow.

Distressed Real Estate Workouts, Trades and Loan Purchases: Tax Consequences Matter

USA - April 29 2020 The COVID-19 pandemic has been wreaking havoc on the economy generally, and with respect to many asset classes of real estate, specifically, and the…

Steven L Lichtenfeld, Stuart L Rosow.

Proposed Regulations on Built-in Gains and Losses under Section 382(h)

USA - September 19 2019 On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the…

Alan P Parnes, Martin T Hamilton, Muhyung (Aaron) Lee.

State Tax on Trust Income Based Solely on In-State Residence of Beneficiaries Found Unconstitutional

USA - July 3 2019 On June 21, 2019, the United States Supreme Court decided North Carolina Dept. Of Revenue v. Kimberly Rice Kaestner 1992 Family Trust (hereinafter…

Christine N. Sherman, David S. Miller, Mitchell M Gaswirth, Stuart L Rosow.

Final IRS Regulations Sync Section 956 with TCJA Participation Exemption - Limits “Deemed Dividends” for U.S. Corporate Shareholders of CFCs

USA - May 30 2019 Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned…

Amanda H Nussbaum, David S. Miller, Jeremy Naylor, Malcolm Hochenberg, Martin T Hamilton.