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Results 6 to 10 of 11
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Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

USA - April 21 2016 On April 4, 2016, the US Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) announced proposed regulations (the Proposed...

Laurence J. Stein, Jocelyn F. Noll, Nicholas J. DeNovio, Diana S. Doyle, Jiyeon Lee-Lim.


Treasury Issues Stringent Inversion Regulations, Proposes Far-Reaching Related-Party Debt Rules

USA - April 21 2016 On April 4, 2016, the US Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS) issued new regulations (the Temporary...

Laurence J. Stein, Jocelyn F. Noll, Nicholas J. DeNovio, Diana S. Doyle, Jiyeon Lee-Lim.


Congress Enacts Significant Changes to the REIT and FIRPTA Rules

USA - December 23 2015 On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (Act), also known as the PATH Act. The Act...

Ana G. O’Brien.


IRS proposes guidance on real property definition for REIT purposes

USA - May 15 2014 On May 14, 2014, the Internal Revenue Service (IRS) published in the Federal Register proposed regulations that clarify the definition of “real...

Ana G. O’Brien, Eric Cho.


IRS to resume work on REIT conversion ruling requests

USA - November 22 2013 On November 14, the Internal Revenue Service (IRS) contacted at least three companies (Equinix, Iron Mountain and Lamar Advertising) informing them...

David S. Raab, Ana G. O’Brien, Pardis Zomorodi.