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New IRS Revenue Procedure 2018-48 Provides Welcome Relief for REITs with International Operations

USA - September 17 2018 On September 13, 2018, the Internal Revenue Service (Service) published revenue procedure 2018-48 (Revenue Procedure), concerning the proper treatment...

David C. Miller.


The House’s Proposed Tax Cuts and Jobs Act and REITs

USA - November 3 2017 On November 2, Chairman of the House Committee on Ways and Means, Representative Kevin Brady R.-TX), introduced the Tax Cuts and Jobs Act and an...

Robert M. Kreitman.


Tax Court Rejects IRS Revenue Ruling 91-32: Important Development for Foreign Investors

USA - July 24 2017 On July 13, 2017, the U.S. Tax Court (Tax Court) issued a 55-page opinion rejecting the long-standing position of the Internal Revenue Service (IRS)...

Laura M. Barzilai.


Delaware Supreme Court Affirms Ruling Allowing Termination of Merger Based on Failure to Deliver a Required Tax Opinion

USA - April 6 2017 On March 23, 2017, the Delaware Supreme Court, in a 4-to-1 decision, affirmed the Court of Chancery's denial of The Williams Companies, Inc.'s...

Jack B. Jacobs, J. Mark Metts, Hille R. Sheppard, Sharp Sorensen, Thomas A. Cole, Scott M. Freeman, John K. Hughes, Paul L. Choi.


Final Debt-Equity Tax Regulations Significantly Narrow the Scope of the Proposed Regulations

USA - October 17 2016 On October 13, 2016, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published final and temporary Treasury regulations on...

Laura M. Barzilai, Daniel Altman, Sharp Sorensen, Tracy D.Williams, Suresh T. Advani.