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IRS Expands REIT Spin-Off Restrictions, Extends REIT Built-in Gains Period to 10 Years

USA - June 8 2016 On June 7, 2016, the Internal Revenue Service (IRS) and Treasury Department issued new temporary regulations that have dramatic implications for all…

Stuart M. Finkelstein, Edward E. Gonzalez, David F. Levy, David Polster, Sarah E. Ralph

Build Back Better Act Would Change Monetization Playbook for Tax-Free Spin-Offs

USA - December 17 2021 If enacted in its present form, the Build Back Better Act (BBBA) would amend the U.S. tax code’s rules for tax-free spin-off and split-off…

Thomas F. Wood

Proposed Excise Tax on Stock Repurchases Has Far-Reaching Implications for Corporate Transactions

USA - November 5 2021 In legislative text released October 28, 2021, the House Rules Committee proposed to impose a 1% excise tax on stock repurchases by publicly traded…

Victor Hollender, David M. Rievman, Eric B. Sensenbrenner, Thomas F. Wood

Build Back Better Act Would Change Monetization Playbook for Tax-Free Spin-Offs

USA - January 19 2022 If enacted in its present form, the Build Back Better Act (BBBA) would amend the U.S. tax code’s rules for tax-free spin-off and split-off…

Thomas F. Wood

IRS Proposes New Section 382 Regulations To Further Limit Use of Tax Losses

USA - September 27 2019 On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing…

Jared H. Binstock, Cliff Gross, Jessica A. Hough, Paul Schockett