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Treasury Adds Color to Grecian Repeal - Proposed Regulations Implement New Section 864(c)(8) for Sale of Partnership Interests by Foreign Partners

USA - January 8 2019 On December 20, 2018, the US Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released proposed regulations (the...

Isaac L. Maron, Kenneth Klein, Michael Lebovitz, JoonBeom Pae, Jared B. Goldberger.


Capital Markets Tax Quarterly - Volume 1, Issue 1

USA - October 19 2018 For our first issue, we couldn’t help but reflect on how things have changed in our little corner of the tax world in the last two years! If you went...

Jason S. Bazar, Russell Nance, Maria Carolina Grecco Bazzanelli, Thomas A. Humphreys, Remmelt Reigersman, David J. Goett, Michael K. Marion, Mark H. Leeds, Jared B. Goldberger.


Tax Reform Income Acceleration Provision Inapplicable to Accrued Market Discount

USA - October 1 2018 On September 27, 2018, the US Internal Revenue Service (the “IRS”) released Notice 2018-80 (the “Notice”),1 announcing that the Treasury Department...

Jason S. Bazar, Thomas A. Humphreys, Remmelt Reigersman, Brennan W. Young, Mark H. Leeds.


IRS Rules Freddie Mac MBS Restructuring Does Not Trigger Gain or Loss

USA - September 4 2018 The United States residential mortgage market is among the most complex financial ecosystems in the world. Although the Federal Home Loan Mortgage...

Steven D. Garden, Russell Nance, Michael K. Marion, Mark H. Leeds.


New Guidance on Interest Deduction Limitation Under Section 163(j)

USA - April 6 2018 On April 2, 2018, the US Treasury Department and the Internal Revenue Service ("IRS") issued Notice 2018-28 (the "Notice") providing guidance relating...

Jason S. Bazar, Minju Kim, Lucas Giardelli.